Does "Subpart C - Recordkeeping Forms and Recording Criteria" Apply to You?

Before you answer yes, the standard, determination of work-relatedness, states that an injury or illness is considered 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 (listed below) specifically applies:

• 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.
• 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.
• 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. 
• 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 would not be considered work-related. Note: If the employee is made ill by ingesting food contaminated by workplace contaminants (such as lead), or gets food poisoning from food supplied by the employer, the case would be considered work-related.
• 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.
• The injury or illness is solely the result of personal grooming, self medication for a non-work-related condition, or is intentionally self-inflicted.
• 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.
• 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.
• The illness is a mental illness. Note: Mental illness is not considered work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related.

For purposes of OSHA injury and illness recordkeeping, a work environment is defined as the establishment and other locations where one or more employees are working or are present as a condition of their employment. The work environment includes not only physical locations, but also the equipment or materials used by the employee during the course of his or her work. An injury or illness is a preexisting condition if it resulted solely from a non-work-related event or exposure that occurred outside the work environment. Preexisting injury or illness has been significantly aggravated an event or exposure in the work environment results in any of the following:

• Death
• Loss of consciousness, provided that the preexisting injury or illness would likely not have resulted in loss of consciousness but for the occupational event or exposure.
• One or more days away from work, or days of restricted work, or days of job transfer that otherwise would not have occurred but for the occupational event or exposure.
• Medical treatment in a case where no medical treatment was needed for the injury or illness before the workplace event or exposure, or a change in medical treatment was necessitated by the workplace event or exposure.

Based on the above information above, was the fatality, injury or illness work-related? If yes, then you need to comply with the standard's requirements and record it on the OSHA 300 Log. The standard also includes requirements for recording injuries involving employees working from home, in travel status, and pre-existing conditions. 

Additional related information can be found on the A-Z safety and health topics page for recording and reporting. Also reference our webpage for reporting a workplace accident.

The standard, determination of new cases, considers an injury or illness a "new case" if:

• The employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body, or 
• The employee previously experienced a recorded injury or illness of the same type that affected the same part of the body but had recovered completely (all signs and symptoms had disappeared) from the previous injury or illness and an event or exposure in the work environment caused the signs or symptoms to reappear.

Does the injury or illness meet the criteria above? If yes, then you need to comply with the standard's requirements and record it on the OSHA 300 Log. 

Note: Injuries and illnesses are recordable only if they are new, work-related cases that meet one or more of the part 1904 recording criteria.

Additional related information can be found on the A-Z safety and health topics pages for medical services and first aid and recording and reporting. Also reference our webpage for reporting a workplace accident.

An injury or illness is considered to meet the general recording criteria, and therefore recordable, if it results in any of the following:

• Death  (report within 8 hours to OSHA);
• Days away from work;
• Restricted work or transfer to another job;
• Medical treatment beyond first aid;
• Loss of consciousness; or
• Significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.

Did the injury or illness result in death, days away from work, restricted work or transfer to another job, medical treatment, loss of consciousness or a significant injury or illness? If yes, then you need to comply with general recording criteria and record on the OSHA 300 Log.

The standard also covers how to record an employee's death, injuries/illnesses resulting in days away from work, counting days (i.e.; day of injury, weekends, holidays), employee not following recommendations provided by licensed healthcare professional, recording injuries/illnesses that result in restricted work or job transfer, and definitions.

Medical treatment means the management and care of a patient to combat disease or disorder. For the purposes of the recordkeeping standard, 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 below.

First aid means the following:

• Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
• Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment);
• Cleaning, flushing or soaking wounds on the surface of the skin;
• Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
• Using hot or cold therapy;
• Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
• Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.).
• Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
• Using eye patches;
• Removing foreign bodies from the eye using only irrigation or a cotton swab;
• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
• Using finger guards;
• Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
• Drinking fluids for relief of heat stress.

Significant injury or illness means work-related cases involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum must always be recorded under the general criteria at the time of diagnosis by a physician or other licensed health care professional.

Additional related information can be found on the A-Z safety and health topics pages for medical services and first aid, bloodborne pathogens, and recording and reporting. Also reference our webpage for reporting a workplace accident.

If yes, then you need to comply with the recordkeeping requirements for recording criteria for needlestick and sharps injuries. All work-related needlestick injuries and cuts (i.e., cuts, lacerations, punctures, scratches) from sharp objects that are contaminated with another person's blood or other potentially infectious material must be recorded on the OSHA 300 Log as an injury. Note: To protect the employee's privacy, you may not enter the employee's name on the OSHA 300 Log.

Other Potentially Infectious Materials (OPIM) means:

• The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids; 
• Any unfixed tissue or organ (other than intact skin) from a human (living or dead); and 
• HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV. 

Additional related information can be found on the A-Z safety and health topics pages for medical services and first aid, bloodborne pathogens, and recording and reporting. 

If yes, then you need to comply with the standard, criteria for cases involving medical removal under OSHA standards and record the case on the OSHA 300 Log. Many of the health standards in general industry, construction, and shipyard employment have medical surveillance requirements that pertain to medical removal such as lead, cadmium, methylene chloride, formaldehyde, and benzene. 

Additional information can be found on the A-Z topics pages for asbestos, beryllium, lead, formaldehyde, tuberculosis, noise and recording and reporting.   

Did the employee's hearing test (audiogram) reveal that the employee experienced a work-related Standard Threshold Shift (STS) in hearing in one or both ears, and the employee's total hearing level is 25 decibels (dB) or more above audiometric zero (averaged at 2000, 3000, and 4000 Hz) in the same ear(s) as the STS? If yes, then you need to comply with the standard on recording criteria for cases involving occupational hearing loss and record the case on your OSHA 300 Log. It includes requirements pertaining to baseline audiograms, adjustment for the effects of aging on hearing, and retesting.

A Standard threshold shift is defined as a change in hearing threshold, relative to the baseline audiogram for that employee, of an average of 10 decibels (dB) or more at 2000, 3000, and 4000 hertz (Hz) in one or both ears.

The standard also covers requirements pertaining to affects of aging on hearing loss and retesting. Additional related information can be found on the A-Z safety and health topics pages for medical services and first aid, noise, and recording and reporting. 

After the exposure, did the employee subsequently develop a tuberculosis infection, as evidenced by a positive skin test or diagnosis by a physician or other licensed health care professional? If yes, then you must comply with recording criteria for work-related tuberculosis cases and record the case on the OSHA 300 Log by checking the "respiratory condition" column.

Additional related information can be found on the A-Z safety and health topics pages for medical services and first aid, tuberculosis and recording and reporting.