OSHA 300 Logs: How to Determine Whether to Record an Injury or Illness

Author: Stephen Glazier

Employers with more than 10 employees at any time during a calendar year and who aren't partially exempt must keep Occupational Safety and Health Administration (OSHA) 300 and 300 A logs of workplace injuries and illnesses. When keeping 300 logs and 300 A summary records, accuracy is essential — overreporting can result in unnecessary regulatory attention.

Accuracy in 300 log and 300 A recordkeeping can mean the difference between winning or losing a contract or having to submit a time-consuming corrective action plan related to an above-average recordable case rate, lost time case rate or other OSHA statistic. Even if your company doesn't win or lose contracts based on OSHA statistics, these rates can still be important because high rates can put your company on an OSHA enforcement programming target list or cause OSHA enforcement visits to expand and drag on longer than necessary.

Another consideration is that OSHA requires employers to give employees, former employees or employee representatives access to the 300 log.¹ Having non-recordable injuries recorded on the log is rarely a good thing.

Many times, the individual responsible for keeping accurate OSHA logs isn't the same person who deals with contracts and new business. This often leads to a natural disconnect and potential misunderstanding between the goal of limiting recordable cases to only those required by regulation and the desire that nothing that should be on the 300 log is missed. The keys to balancing these two goals are accuracy and strategic planning.

This article will concentrate on three steps you can take to ensure only recordable cases end up on the 300 log.

Step 1: Determine if the injury or illness is work-related

The first and most important question is whether the injury or illness in question is work-related. Standard 29 CFR 1904.5² deals with this topic. If it isn't work-related, the case isn't recordable and those keeping the log can simply stop here.

Many times, those keeping logs will skip past the question of work-relatedness and move straight to medical treatment and other triggers. Moving too quickly through this step can cause cases to end up on the log that don't belong there. One example would be a heart attack that occurs at work. An employee may lose consciousness, be admitted to the hospital and ultimately die from a heart attack that occurs at work. All the above outcomes would cause a case to be recordable, but only if an event at work contributed to the heart attack. The employer has to look at the facts and decide.

OSHA Example:

Reference: 5-8

Question: If an employee's pre-existing medical condition causes an incident which results in a subsequent injury, is the case work-related? For example, if an employee suffers an epileptic seizure, falls, and breaks his arm, is the case covered by the exception in section 1904.5(b)(2)(ii)?

Answer:

Neither the seizures nor the broken arm are recordable. Injuries and illnesses that result solely from non-work-related events or exposures are not recordable under the exception in section 1904.5(b)(2)(ii). Epileptic seizures are a symptom of a disease of non-occupational origin, and the fact that they occur at work does not make them work-related. Because epileptic seizures are not work-related, injuries resulting solely from the seizures, such as the broken arm in the case in question, are not recordable.

For more information, explore OSHA's Recordkeeping Requirements.

Standard Number: 1904.5, 1904 - Table of Contents

What if the workers' compensation carrier deems the injury compensable?

Even if the WC carrier determines a claim is work-related and compensable, it may not be work-related for OSHA log-keeping purposes. The opposite can be true as well. A companion article to this one examines whether all denied WC cases should be removed from the 300 log. That article lays the foundation for understanding the difference between the workers' compensation system and OSHA recordability regulations.

In making a work-relatedness determination, OSHA states that injuries occurring in the physical workplace are presumed to be work-related, but they also provide employers with a list of injury and illness causations which, even if they occur at work, even if they are considered compensable via worker's compensation statute, aren't considered work-related for recordkeeping purposes and don't need to be put on the log. The list below can be found at 1904.5(b)(2).²

OSHA states that you aren't required to record injuries and illnesses if:

1. At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee.
2. The injury or illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside the work environment.
3. The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball or baseball.
4. The injury or illness is solely the result of an employee eating, drinking or preparing food or drink for personal consumption (whether bought on the employer's premises or brought in). For example, if the employee is injured by choking on a sandwich while in the employer's establishment, the case wouldn't be considered work-related. (Note: If the employee becomes ill by ingesting food contaminated by workplace contaminants [such as lead], or gets food poisoning from food the employer supplies, the case would be considered work-related.)
5. The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee's assigned working hours.
6. The injury or illness is solely the result of personal grooming, self-medication for a non-work-related condition or is intentionally self-inflicted.
7. The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work.
8. The illness is the common cold or flu. (Note: contagious diseases such as tuberculosis, brucellosis, hepatitis A or plague are considered work-related if the employee is infected at work).
9. The illness is a mental illness. Mental illness isn't considered work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed healthcare professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related.

While the above list is helpful, it does have to be carefully applied. This fact was colorfully illustrated during the COVID-19 pandemic. Because COVID-19 wasn't considered the "common cold or flu" (point 8) by OSHA, employers were faced with using the typical flow of deciding if the case was work-related, medical treatment was given, time was lost from work or work accommodations were given.

The FAQ on OSHA's recordkeeping page³ is a useful tool in helping make work-relatedness determinations.

While not addressed in this article, other questions Standard 1904.5² addresses include:

• When a pre-existing condition has been "significantly re-aggravated" and becomes recordable.
• When an injury to a traveling employee might be considered recordable and when it wouldn't.
• When a work-at-home employee's injury is considered work-related and when it isn't.

Step 2: Determine if medical treatment was rendered

The second question to ask is whether medical treatment was rendered (Standard 29 CFR 1904.7⁴).

According to OSHA, first aid isn't considered medical treatment regardless of who applies it. OSHA has a list of first aid treatments in 1904.7(b)(5)(ii)⁵ that is all-inclusive. In other words, if the only treatments given are on the first-aid list, the case isn't recordable unless another trigger such as loss of consciousness, lost time or another separately listed trigger occurs. This is true even if a medical doctor or other healthcare professional renders the first aid.

An area of confusion can occur here when a medical professional performs diagnostic procedures. While not referenced in the first aid list, diagnostic procedures and even hospital-administered diagnostics or observation don't make a case recordable on their own. They aren't considered medical treatment. A case of this type would only be recordable if another trigger occurs. Read through step 3 for additional discussion around additional triggers.

OSHA examples:

Reference: 7-27

Question: If an employee has x-rays or other diagnostic procedures, does that make a case recordable?

Answer:

No. X-rays and other diagnostic procedures are not considered medical treatment and do not make a case recordable per section 1904.7(b)(5)(i)(B).

For more information, explore OSHA's Recordkeeping Requirements.

Standard Number: 1904.7, 1904 - Table of Contents

What is the definition of medical treatment?

1904.7(b)(5)(i) — (i)(c) defines Medical Treatment: "Medical treatment" means the management and care of a patient to combat disease or disorder. For the purposes of Part 1904, medical treatment does not include: Visits to a physician or other licensed health care professional solely for observation or counseling; The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils); or "First aid" as defined in paragraph (b)(5)(ii) of this section.

Step 3: Determine if other recordability triggers apply

If you determine that an injury is work-related but medical treatment wasn't administered, you need to rule out a few additional triggers. If any of these triggering outcomes occur, the case is deemed recordable (Standard 29 CFR 1904.7⁴).

• Death: A work-related death is always recordable.
• Days away from work: If an injury is work-related and results in days away from work, the case is always recordable. It should be noted that whether the physician or the employer determines that the employee can't work as a result of the injury, the days missed would be recorded as days away from work, and the case would be recordable.
• Restricted work or transfer to another job: Work-related injuries that result in restricted duty are always recordable. For a case to qualify as a restricted duty case, the employer or physician must preclude an employee from performing one or more of their routine functions. OSHA defines routine functions as "work activities the employee regularly performs at least once per week."
• Loss of consciousness: A work-related injury resulting in a loss of consciousness is always recordable.
• A significant work-related injury or illness that a physician or other licensed healthcare professional diagnoses is always recordable. This includes work-related cases involving cancer, chronic irreversible disease, a fractured or cracked bone or a punctured eardrum.
• Contaminated sharps exposure: Employers must record all work-related needlestick injuries and cuts from sharp objects that are contaminated with another person's blood or other potentially infectious material as defined by 29 CFR 1910.1030⁶. In this case, the employee's name isn't recorded on the log.
• Work-related hearing standard threshold shifts, as defined by 29 CFR 1904.10⁷, must be recorded on the 300 log.
• Work-related tuberculosis infections must be recorded on the 300 log.

Use the flow chart below as a high-level guide for making a recordability decision.

Depending on the strategy the employer uses and who has been keeping the OSHA logs, it's not uncommon to find multiple non-recordable entries on the logs. Many times, this is done with the best of motives. If, in reviewing your logs, you find yourself questioning some of the entries, reach out to your Gallagher representative with questions.

Published June 2026