How to Determine if an Injury is OSHA Recordable: A Complete Guide for Small Business Owners
If you run a delivery business, warehouse, or any operation with employees, you've probably faced this question: "Do I need to report this injury to OSHA?" The answer isn't always obvious, and getting it wrong can lead to compliance issues during inspections.
This guide breaks down exactly how to determine if a workplace injury is OSHA recordable, with practical examples from real delivery and logistics scenarios.
Understanding the Stakes
OSHA recordkeeping matters for three reasons:
1. Legal compliance - Many employers are required to keep OSHA records depending on establishment size and industry
2. Inspection readiness - OSHA can request logs during inspections or audits
3. Risk management - Accurate records help identify workplace hazards before they escalate
OSHA penalties can be significant and change over time. The bigger risk is usually under-recording or being unable to explain your log later. Aim for accuracy, and when you’re unsure, go back to the primary rules (29 CFR 1904) or consult a qualified professional. Not legal advice.
The 3 Recordability Criteria
An injury or illness is OSHA recordable only when ALL three criteria are met:
1. Work-Related
The injury occurred in the work environment and was caused by work activities or conditions.
Work environment includes:
- Company facilities (warehouses, offices, break rooms)
- Customer locations during deliveries
- Vehicles during work hours
- Parking lots when arriving/departing for work
Common exceptions (NOT work-related):
- Pre-existing conditions that didn't worsen at work
- Injuries from purely personal tasks (eating lunch, personal phone calls)
- Commuting accidents (unless in company vehicle during work duties)
2. New Case
This is the first time this specific injury has been recorded, OR it's a significant re-injury after full recovery.
New case criteria:
- Employee hasn't experienced a recordable injury to the same body part, OR
- Employee fully recovered from previous injury, OR
- Previous injury was only first aid, now requires medical treatment
Not a new case:
- Continuation of previously recorded injury
- Follow-up treatment for existing recordable case
3. Meets One or More General Recording Criteria
The injury resulted in:
1. Death
2. Days away from work - Employee cannot perform their regular job duties
3. Restricted work or job transfer - Employee can work but with limitations
4. Medical treatment beyond first aid - More than bandages, ice, over-the-counter meds
5. Loss of consciousness
6. Significant injury diagnosed by a physician - Fractures, torn ligaments, herniated discs, chronic conditions
First Aid vs. Medical Treatment: The Critical Distinction
Many recordability determinations hinge on this question: Was it first aid or medical treatment?
First Aid (NOT Recordable)
- Cleaning, flushing, or soaking wounds
- Applying bandages, butterfly bandages, Steri-Strips
- Using elastic bandages or finger guards
- Applying hot/cold therapy (ice packs, heating pads)
- Non-prescription medications at non-prescription strength
- Tetanus shots
- Removing splinters or foreign material from eyes (without instruments)
- Drinking fluids to relieve heat stress
Medical Treatment (Recordable)
- Stitches or staples
- Prescription medications at any strength OR over-the-counter meds at prescription strength
- Physical therapy or chiropractic treatment
- Treatment of second or third-degree burns
- Removing foreign objects embedded in the eye (requiring instruments)
- Any treatment in a series (multiple visits for the same injury)
- Application of casts, splints, negative pressure wound therapy
Example:* An employee cuts their hand on a box cutter. The supervisor cleans the wound and applies a bandage. **First aid only - NOT recordable.** The same cut requires 6 stitches at urgent care. *Medical treatment - RECORDABLE.
Decision Flowchart: Is This Injury OSHA Recordable?
```
START: Injury or illness occurred
|
v
Did it happen in the work environment?
(Company facility, delivery route, work vehicle, customer location during work)
|
|--NO--> NOT RECORDABLE (not work-related)
|
|--YES--> Continue
v
Is this a new case?
(First occurrence or significant re-injury after full recovery)
|
|--NO--> NOT RECORDABLE (continuation of existing case)
|
|--YES--> Continue
v
Does the injury meet ANY of these criteria?
- Death
- Days away from work
- Restricted work/job transfer
- Medical treatment beyond first aid
- Loss of consciousness
- Significant injury diagnosed by physician (fracture, etc.)
|
|--NO--> NOT RECORDABLE (first aid only)
|
|--YES--> RECORDABLE
v
Record on OSHA Form 300 within 7 calendar days
```
Real-World Scenarios with Recordability Determinations
Scenario 1: Parking Lot Slip and Fall
Situation: Employee arrives for their morning shift at 6:00 AM. While walking from their personal vehicle across the company parking lot, they slip on ice and fall, fracturing their wrist. They go to the ER and are placed on restricted duty (no lifting) for 6 weeks.
Analysis:
- Work-related? YES - Company parking lot during arrival for work
- New case? YES - First occurrence
- General recording criteria? YES - Significant injury (fracture) + restricted work
Determination: RECORDABLE
Record as injury, check "job transfer or restriction" box, document 42 days of restricted duty.
Scenario 2: Back Strain Lifting Heavy Packages
Situation: Delivery driver reports lower back pain after lifting a 70-pound package. They see their doctor, who prescribes muscle relaxers and recommends 3 days of rest. Driver returns to full duty after 3 days.
Analysis:
- Work-related? YES - Lifting packages is core job duty
- New case? YES - First report of back injury
- General recording criteria? YES - Prescription medication + days away from work
Determination: RECORDABLE
Record as injury, check "days away from work" box, document 3 days away.
Scenario 3: Vehicle Accident During Delivery Route
Situation: Driver is rear-ended at a red light while on their delivery route. They experience neck pain and see a chiropractor for treatment over the next 2 weeks. No days away from work, no restrictions.
Analysis:
- Work-related? YES - Accident occurred during work duties in company vehicle
- New case? YES - First occurrence
- General recording criteria? YES - Chiropractic treatment qualifies as medical treatment beyond first aid
Determination: RECORDABLE
Record as injury, check "other recordable cases" box (medical treatment but no days away or restrictions).
Scenario 4: Minor Cut Treated On-Site
Situation: Warehouse employee cuts their finger on a box cutter while opening packages. Supervisor immediately cleans the wound with antiseptic, applies pressure to stop bleeding, and wraps it with a bandage. Employee continues working with no restrictions.
Analysis:
- Work-related? YES - Injury occurred during work task
- New case? YES - First occurrence
- General recording criteria? NO - Only first aid administered (cleaning, bandaging)
Determination: NOT RECORDABLE
Document in first aid log if your company maintains one, but do NOT record on Form 300.
Scenario 5: Heat Exhaustion During Summer Route
Situation: Driver experiences dizziness and nausea during a hot summer day. They drink water and electrolytes provided by supervisor, rest in air-conditioned break room for 30 minutes, and return to work. No medical treatment sought.
Analysis:
- Work-related? YES - Symptoms occurred during work in hot weather
- New case? YES - First occurrence
- General recording criteria? NO - Drinking fluids for heat stress is first aid
Determination: NOT RECORDABLE
Drinking fluids to relieve heat stress is explicitly listed as first aid. However, if the employee lost consciousness or sought medical treatment beyond fluids and rest, it would become recordable.
Scenario 6: Aggravated Pre-Existing Condition
Situation: Employee has chronic knee arthritis (disclosed during hiring). While climbing stairs at a delivery location, their knee buckles and they fall, requiring surgery for a torn meniscus.
Analysis:
- Work-related? YES - Work activity (climbing stairs) significantly aggravated the condition beyond its natural progression
- New case? YES - New acute injury (torn meniscus) distinct from chronic condition
- General recording criteria? YES - Surgery qualifies as medical treatment + likely days away
Determination: RECORDABLE
Pre-existing conditions become recordable when work activities cause them to worsen beyond their normal progression. The torn meniscus is a new acute injury caused by the work-related fall.
Scenario 7: Twisted Ankle with Over-the-Counter Treatment
Situation: Employee twists their ankle while stepping off a loading dock. They visit urgent care, where a physician recommends RICE (rest, ice, compression, elevation) and suggests taking ibuprofen (Advil) 200mg every 6 hours as needed - the standard over-the-counter dosage. No days away, no restrictions.
Analysis:
- Work-related? YES - Injury at company facility during work
- New case? YES - First occurrence
- General recording criteria? NO - Over-the-counter medication at non-prescription strength is first aid
Determination: NOT RECORDABLE
Key detail: The ibuprofen was recommended at standard OTC strength (200mg), not prescription strength (800mg). If the physician had prescribed 800mg ibuprofen, it would be recordable as medical treatment.
Scenario 8: Carpal Tunnel Syndrome from Repetitive Tasks
Situation: Warehouse worker experiences wrist pain and numbness after months of repetitive scanning and lifting. Diagnosed with carpal tunnel syndrome by a physician. Treated with wrist splints and modified duties (no heavy lifting) for 3 months.
Analysis:
- Work-related? YES - Repetitive job tasks caused or contributed to the condition
- New case? YES - First diagnosis and recording
- General recording criteria? YES - Physician diagnosis + restricted work
Determination: RECORDABLE
Chronic conditions from repetitive work are recordable when diagnosed by a physician and meet recording criteria. Record as illness (not injury), check "job transfer or restriction" box.
The Conservative Approach: When in Doubt, Record It
Here’s the reality: reviewers tend to look for missing entries and inconsistent logs. But over-recording can also create problems (inflated rates, confusion, and extra follow-up work). The goal is accuracy and consistency, not “record everything.”
Best practice decision framework:
1. Clear first aid? → Document in first aid log, don't record on Form 300
2. Clear recordable? → Record on Form 300 within 7 days
3. Uncertain? → Record it. You can always explain during an audit why you chose the conservative path.
Common gray areas where you should record:
- Employee visits a doctor but only receives first aid treatment (record it - the visit itself indicates more than minor)
- Injury seems minor but employee misses work (always recordable if days away)
- Prescription medication is mentioned but you're unsure if it was actually given (assume yes, record it)
- Injury happens in parking lot during arrival/departure (record it - work-related)
Recordkeeping Requirements Summary
Once you determine an injury is recordable:
1. Record within 7 calendar days on OSHA Form 300 (Log of Work-Related Injuries and Illnesses)
2. Complete Form 301 (Incident Report) with full details
3. Update day counts as the case progresses (days away, days restricted)
4. Post Form 300A (Annual Summary) from February 1 - April 30 each year
5. Retain records for 5 years from the year the injury occurred
Electronic submission requirements:
- Employers with 250+ employees: Submit Forms 300, 301, and 300A annually
- Employers with 20-249 employees in high-hazard industries: Submit Form 300A annually
- Submission deadline: March 2 each year
What About Electronic Filing via OSHA's ITA Portal?
The Injury Tracking Application (ITA) is OSHA's electronic submission system. Rather than submitting paper forms, covered employers upload CSV files or manually enter data through the portal.
Who must file electronically:
- All establishments with 250+ employees
- Establishments with 20-249 employees in designated high-hazard industries (includes courier/delivery services under NAICS 492)
Even if electronic filing is required, you must still maintain complete Form 300, 301, and 300A records at your establishment. The ITA submission is IN ADDITION to recordkeeping, not a replacement.
For small delivery businesses (Amazon DSP contractors, independent courier services), if you have 20+ employees, you likely need to submit Form 300A data annually via the ITA portal.
Common Mistakes to Avoid
Mistake 1: Not recording "minor" injuries that required medical treatment
Even if an employee works through an injury, if they received stitches, prescription medication, or physical therapy, it's recordable.
Mistake 2: Waiting for final diagnosis to record
Record based on the initial treatment. If an employee goes to the ER and gets prescription pain medication, record it immediately - don't wait to see if they need follow-up care.
Mistake 3: Removing entries after the fact
Once recorded, entries should stay on Form 300 even if the injury healed faster than expected. Update day counts, but don't erase the entry.
Mistake 4: Not recording parking lot injuries
Parking lot injuries during arrival/departure for work are presumed work-related unless evidence shows otherwise.
Mistake 5: Assuming all doctor visits = recordable
If the doctor only provides first aid (bandages, OTC medication at standard strength), it's still first aid. The visit location doesn't automatically make it recordable.
Getting Help with OSHA Compliance
Determining recordability can be complex, especially for gray-area cases. If you're managing OSHA compliance for a small fleet or delivery operation, you don't have to do it alone.
If you want an easier workflow, we’re building an OSHA recordkeeping helper for small businesses to turn messy incident notes into organized, reviewable outputs aligned to 29 CFR 1904. Join the waitlist at SmallBizAutomations.com. Not legal advice.
Additional resources:
- OSHA Recordkeeping Handbook: osha.gov/recordkeeping/handbook
- OSHA Regional Offices: Free compliance assistance (not enforcement-focused)
- Industry associations: Many provide recordkeeping guidance for specific sectors
Final Thoughts: Compliance is About Consistency
OSHA recordkeeping isn't about perfection - it's about good-faith effort and consistent application of the rules. If you:
1. Understand the three recordability criteria
2. Apply them consistently across all injuries
3. Choose the conservative path when uncertain
4. Maintain complete records for 5 years
...you'll be well-prepared for any OSHA inspection or audit.
Remember: The goal isn't zero recordables (that's unrealistic for most operations). The goal is accurate tracking so you can identify patterns, prevent future injuries, and demonstrate your commitment to workplace safety.
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Want an easier workflow for messy records? We’re building an OSHA recordkeeping helper for small businesses that turns scattered incident notes into organized, reviewable outputs aligned to 29 CFR 1904. Join the waitlist at SmallBizAutomations.com or email [email protected]. Not legal advice.