Which Incidents Do You Actually Have to Report to OSHA?
You run a delivery company with 120 vans. One of your drivers slips on ice in the parking lot and sprains their ankle. Do you need to report that to OSHA?
What if they just needed an ice pack and were back on route the next day? What if they were out for two weeks?
Most small business owners have no idea where the line is between "incidents we track" and "incidents OSHA requires us to record." And OSHA's official guidance reads like it was written by lawyers for lawyers.
Let's fix that.
The Problem: OSHA Rules Are Written in Government Speak
Here's what OSHA's official website says about recordability:
> "You must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness."
Thanks, OSHA. Super helpful.
What does "medical treatment beyond first aid" mean? Is a tetanus shot medical treatment? What about a prescription for ibuprofen? What if the doctor just looked at it and said "you're fine"?
The Simple Answer: Three Questions
An incident is OSHA recordable if you answer YES to all three questions:
1. Did it happen at work? (Work-related)
2. Is this a new injury or illness? (Not a pre-existing condition)
3. Does it meet one of the severity criteria? (See below)
If you answer YES to all three, you need to record it on your OSHA 300 Log.
The Severity Criteria (The Real Question)
This is where it gets tricky. An incident meets the severity threshold if it results in ANY of these:
- Death (obviously)
- Days away from work (employee couldn't come in at all)
- Restricted work or job transfer (they came in but couldn't do their normal job)
- Medical treatment beyond first aid (this is the confusing one)
- Loss of consciousness (even briefly)
- Significant injury diagnosed by a physician (fractures, torn ligaments, herniated discs, etc.)
Most confusion comes from "medical treatment beyond first aid." So let's define first aid.
What Is First Aid? (The Stuff You DON'T Report)
OSHA has a specific list of what counts as "first aid." If treatment ONLY involved these things, it's NOT recordable:
- Bandages and wound cleaning
- Ice packs, heating pads, non-rigid supports
- Non-prescription medications at non-prescription strength (regular Advil is fine, prescription-strength ibuprofen is not)
- Tetanus shots (this is the ONE shot that's considered first aid)
- Finger guards, elastic bandages
- Removal of splinters or foreign material from the eye (without tools)
- Hot/cold therapy
- Drinking fluids for heat stress
The key word: ONLY. If the treatment involved ONLY these things, it's first aid. If it involved anything MORE than these things, it's recordable.
Real Examples: Recordable or Not?
Let's walk through some actual scenarios:
Scenario 1: Sprained Ankle, Ice Pack, Back to Work
What happened: Driver slips on ice, twists ankle, supervisor gives ice pack, driver finishes shift with slight limp.
Recordable? NO. Treatment was first aid only (ice pack), and employee didn't miss work or have restricted duty.
Scenario 2: Sprained Ankle, Doctor Visit, Prescription
What happened: Same slip, but driver goes to doctor. Doctor prescribes prescription-strength anti-inflammatory and says "stay off it for 3 days."
Recordable? YES. Prescription medication is medical treatment beyond first aid, AND employee had days away from work.
Scenario 3: Cut Hand, Butterfly Bandage
What happened: Warehouse worker cuts hand on box, supervisor closes it with butterfly bandage (steri-strips), worker continues shift.
Recordable? NO. Butterfly bandages are considered first aid. No days away, no restricted work.
Scenario 4: Cut Hand, Stitches
What happened: Same cut, but deeper. Worker goes to urgent care, gets 4 stitches, returns to work next day with bandaged hand but does normal job.
Recordable? YES. Stitches are medical treatment beyond first aid. Even though worker didn't miss time or have restrictions, stitches alone make it recordable.
Scenario 5: Back Pain, Chiropractor
What happened: Driver has back pain after lifting packages, goes to chiropractor for adjustment.
Recordable? YES. Chiropractic treatment is considered medical treatment beyond first aid.
Scenario 6: Broken Finger, Light Duty
What happened: Mechanic breaks finger, doctor puts it in a splint, mechanic comes back to work but can't use tools so does paperwork instead.
Recordable? YES. Two reasons: (1) Fracture diagnosed by physician is significant injury, (2) Job transfer/restricted work (paperwork instead of mechanics).
The Conservative Rule: When in Doubt, Record It
Here's what OSHA compliance experts tell small businesses: If you're not sure, record it.
Why? Because the penalty for NOT recording something you should have recorded is much worse than recording something you didn't have to.
OSHA can fine you for failing to record. They won't fine you for recording too much.
The Paperwork Burden (Why This Matters)
You might be thinking: "Okay, so I record it. What does that mean?"
For each recordable incident, you need to:
1. Add it to your OSHA 300 Log (the running list of incidents)
2. Fill out an OSHA 301 Incident Report (detailed form about what happened)
3. Post your annual summary (OSHA 300A) in the workplace every February through April
4. Keep these records for 5 years
If you have 10 or fewer employees, OR you're in a low-hazard industry (like retail or finance), you're exempt from keeping the 300 Log. But you still need to report severe incidents (hospitalization, amputation, death) within 24 hours.
The Real Problem: Your Records Are a Mess
Even if you know WHICH incidents to record, most small business owners struggle with HOW to record them.
Your incident "records" probably look like this:
- A text from a supervisor: "Mike hurt his back, went to ER"
- An email from payroll: "Sarah out 3 days - workers comp claim"
- A workers comp form from your insurance company
- A spreadsheet someone started 2 years ago and abandoned
Then OSHA deadline hits (February 1st for posting your annual summary), and you panic.
The Solution: Turn Chaos Into Compliance
This is exactly why we’re building an OSHA recordkeeping helper for small businesses. The idea is simple: you upload whatever you have:
- Texts from supervisors
- Email threads about injuries
- Workers comp claims
- Half-finished spreadsheets
- Literally anything with injury info
The workflow we’re building extracts incident details, applies the recordkeeping decision tree, asks clarifying questions when data is missing, and helps you generate the outputs you need:
- OSHA Form 300 (log)
- OSHA Form 300A (annual summary)
- OSHA Form 301 (incident report details)
- ITA-ready CSV (if you’re required to submit electronically)
No magic. Just fewer messy handoffs and fewer “January rebuild” surprises.
Join the waitlist at SmallBizAutomations.com (not legal advice)
Key Takeaways
1. Three-part test: Work-related + New case + Severity criteria
2. First aid is clearly defined: If treatment only involved OSHA's first aid list, it's NOT recordable
3. Medical treatment beyond first aid: Stitches, prescriptions, physical therapy, chiropractic care = recordable
4. When uncertain, slow down: Re-check the primary rule (29 CFR 1904) or ask a qualified pro
5. Paperwork deadline: Annual summary (300A) must be posted February 1 - April 30
6. The real challenge isn't knowing the rules, it's organizing your messy records into compliant forms
Stop guessing. Start complying. Upload your records and let us handle the OSHA paperwork.