Compliance Overview: Identifying OSHA Recordable Incidents

MyTPG Blog
Published: 07/8/20 7:08 AM

Identifying OSHA Recordable Incidents banner | TPG

Compliance Overview: Identifying OSHA Recordable Incidents

This article was published on: 07/8/20 7:08 AM

The Occupational Safety and Health Act (OSH Act) generally requires covered employers to prepare and maintain records of occupational injuries and illnesses. The Occupational Safety and Health Administration (OSHA) is a part of the U.S. Department of Labor and is responsible for administering the recordkeeping system established by the OSH Act.

Download the PDF version

This Compliance Overview is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.

©2019-2020 All rights reserved.

To comply with OSHA’s recordkeeping rules, employers must first determine which incidents to record. In some cases, this can require a detailed analysis to assess whether an incident is work-related.

Work-related Injuries
An injury or illness is work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness.

This Compliance Overview provides a sample workflow employers can use to determine whether an injury or illness is work-related and must be entered into the organization’s OSHA records. Employers can also reference published OSHA guidance and frequently asked questions in their efforts to determine whether to record a specific incident.

Links and Resources

– OSHA Injury and Illness Recordkeeping and Reporting Requirements website
– OSHA Forms – 300, 300A and 301

OSHA 300 Recordability Flowchart

Determining Work-Relatedness

Employers must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception applies.


  1. Employee Report of Injury/Illness: Injury or illness reported assumes the individual reporting the injury or illness is an employee of ABC Company. If the employee is a temporary employee from a temporary staffing agency, incidents are to be recorded in the 300 log; however, the temporary staffing agency would be responsible for reporting workers’ compensation claims to the carrier.
  2. Occupational Hearing Loss: Defined as:
    • A change in hearing threshold relative to the baseline audiogram as an average of 10 decibels (dB) or more in either ear at 2,000, 3,000 and 4,000 hertz.
    • Employee’s total hearing level of 25 dB or more above audiometric zero in both ears at the same hertz levels.
  3. Medical Treatment:The management and care of a patient to combat disease or disorder. It does not include:
    • Visits to practitioners for observation and/or evaluation only
    • Diagnostic procedures
    • First aid
  4. First Aid: Defined by OSHA regulations (section 1904.7 (b)(5)). Treatments that are considered first aid include:
    • The use of nonprescription medication at nonprescription strength
    • Tetanus immunizations
    • Cleaning, flushing or soaking surface wounds
    • Use of wound coverings, butterfly bandages, Steri-Strips
    • Use of non-rigid means of support
    • Temporary immobilization devices used to transport victims
    • Drilling of fingernails or toenails or draining fluid from a blister
    • Hot or cold therapy
    • Eye patches
    • Removal of foreign bodies from eye using irrigation or cotton swab
    • Removal of splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
    • Finger guards
    • Massage therapy
    • Drinking fluids for relief of heat stress

Exempt Industries

  • Employers in some industries are not required to keep OSHA injury and illness records.
  • OSHA, the Bureau of Labor Statistics (BLS) or a state agency can overrule this exemption by notifying exempt establishments that they are required to create and maintain workplace injury and illness records.

Employers are not required to keep OSHA injury and illness records for any establishment classified in the following North American Industry Classification System (NAICS) codes, unless they are asked in writing to do so by OSHA, the Bureau of Labor Statistics (BLS) or a state agency operating under the authority of OSHA or the BLS.

All employers, including those partially exempted by reason of company size or industry classification, must report to OSHA any workplace incident that results in a fatality within eight hours. They must also report to OSHA within 24 hours the in-hospitalization of at least one employee, an amputation or the loss of an eye (see § 1904.39). The partially exempt industry classifications are listed in the table below.

NAICS CodeIndustry
4412Other Motor Vehicle Dealers
4431Electronics and Appliance Stores
4461Health and Personal Care Stores
4471Gasoline Stations
4481Clothing Stores
4482Shoe Stores
4483Jewelry, Luggage and Leather Goods Stores
4511Sporting Goods, Hobby and Musical Instrument Stores
4512Book, Periodical and Music Stores
4532Office Supplies, Stationery and Gift Stores
4812Nonscheduled Air Transportation
4861Pipeline Transportation of Crude Oil
4862Pipeline Transportation of Natural Gas
4869Other Pipeline Transportation
4879Scenic and Sightseeing Transportation, Other
4885Freight Transportation Arrangement
5111Newspaper, Periodical, Book and Directory Publishers
5112Software Publishers
5121Motion Picture and Video Industries
5122Sound Recording Industries
5151Radio and Television Broadcasting
5172Wireless Telecommunications Carriers (except Satellite)
5173Telecommunications Resellers
5179Other Telecommunications
5181Internet Service Providers and Web Search Portals
5182Data Processing, Hosting and Related Services
5191Other Information Services
5211Monetary Authorities – Central Bank
5221Depository Credit Intermediation
5222Nondepository Credit Intermediation
5223Activities Related to Credit Intermediation
5231Securities and Commodity Contracts Intermediation and Brokerage
5232Securities and Commodity Exchanges
5239Other Financial Investment Activities
5241Insurance Carriers
5242Agencies, Brokerages and Other Insurance- Related Activities
5251Insurance and Employee Benefit Funds
5259Other Investment Pools and Funds
5312Offices of Real Estate Agents and Brokers
5331Lessors of Nonfinancial Intangible Assets (except Copyrighted Works)
5411Legal Services
5412Accounting, Tax Preparation, Bookkeeping and Payroll Services
5413Architectural, Engineering and Related Services
5414Specialized Design Services
5415Computer Systems Design and Related Services
5416Management, Scientific and Technical Consulting Services
5417Scientific Research and Development Services
5418Advertising and Related Services
5511Management of Companies and Enterprises
5611Office Administrative Services
5614Business Support Services
5615Travel Arrangement and Reservation Services
5616Investigation and Security Services
6111Elementary and Secondary Schools
6112Junior Colleges
6113Colleges, Universities and Professional Schools
6114Business Schools and Computer and Management Training
6115Technical and Trade Schools
6116Other Schools and Instruction
6117Educational Support Services
6211Offices of Physicians
6212Offices of Dentists
6213Offices of Other Health Practitioners
6214Outpatient Care Centers
6215Medical and Diagnostic Laboratories
6244Child Day Care Services
7114Agents and Managers for Artists, Athletes, Entertainers and Other Public Figures
7115Independent Artists, Writers and Performers
7213Rooming and Boarding Houses
7221Full-Service Restaurants
7222Limited-Service Eating Places
7224Drinking Places (Alcoholic Beverages)
8112Electronic and Precision Equipment Repair and Maintenance
8114Personal and Household Goods Repair and Maintenance
8121Personal Care Services
8122Death Care Services
8131Religious Organizations
8132Grantmaking and Giving Services
8133Social Advocacy Organizations
8134Civic and Social Organizations
8139Business, Professional, Labor, Political and Similar Organizations

Download the PDF version