Free tools / Recordability
Is this case OSHA recordable? A plain-English walkthrough of 29 CFR 1904.7.
Most online recordability calculators stop at five questions and a yes / no. The rule is bigger than that — work-relatedness, severe-outcome short-circuits, two separate exemption paths (1904.1 size, 1904.2 industry), six general criteria, special cases for hearing loss and tuberculosis and needle-sticks. Get any of them wrong and you've either over-reported (and inflated your TRIR) or under-reported (and earned an OSHA citation when the case surfaces years later). This page walks the whole cascade.
Why this matters
Recordability is the audit trail's first checkpoint.
Every recordable case in 1904.7 lands on an OSHA Form 300, then on Form 300A at the close of the calendar year, then on the Form 300A posting tacked to a wall every February through April. Miss one and the posting is wrong; the posting being wrong is an OSHA citation in its own right (1904.32(b)(5), 1904.32(b)(6)). Get one wrong-way-recordable and your TRIR balloons against your peers in the BLS data. The same cascade also feeds 1904.39 severe-injury reporting deadlines (the 8-hour fatality clock, the 24-hour hospitalisation / amputation / loss-of-eye clock), Form 301 incident reports, and ITA electronic submission for the establishments that qualify.
Most online “recordability calculators” condense the rule to three or four yes / no questions. This page is structured around the rule's actual sub-paragraphs, the same way SE's compliance engine walks them for every customer determination, with the regulatory citations attached so an auditor or insurer can follow your reasoning.
The cascade
How 1904.7 actually decides — eight steps in order.
The cascade short-circuits on the first “Not recordable” that applies. Step through them top to bottom for a single case, and the first match is your answer. Severe outcomes (Step 2) bypass both exemption paths — a fatality on a 6-employee farm is still recordable.
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1
Work-relatedness gate — 1904.5
Was the case caused by an event or exposure in the work environment? If clearly no — not recordable, no need to walk the rest. If yes — continue. If genuinely under investigation, the determination waits.
Common gotchas: employee fell ill at work from a non-work cause (cold, personal medication side-effect — see the 1904.5(b)(2) exceptions); parking-lot injury during commute (generally not work-related, but case law varies); mental-health diagnosis after a workplace event (work-related if a healthcare professional links it; you don't make the call yourself).
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2
Severe-outcome short-circuit — 1904.7(b)(2)
Fatality, overnight (in-patient) hospitalisation, amputation of any limb or digit, or loss of vision in either eye. Any one of these means recordable + reportable (1904.39), and the cascade skips both exemption paths below. Severe outcomes get recorded regardless of employer size or NAICS.
Reporting clock: fatality — 8 hours; hospitalisation / amputation / loss-of-eye — 24 hours. The clock starts when the employer learns of the outcome, not when the event happened.
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3
Size exemption — 1904.1
Did the establishment have 10 or fewer employees at any point during the previous calendar year? If yes, general 1904.7 recording does not apply (except for severe outcomes from Step 2 and reportable events from 1904.39). Otherwise — continue.
Count carefully: the 10-employee threshold is the peak headcount across the prior calendar year, not an average; part-time and seasonal employees count. Multi-establishment employers count per establishment, not company-wide.
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4
Partial-industry exemption — 1904.2 + Appendix A
Is the establishment's NAICS four-digit industry group on the 1904.2 Appendix A partially-exempt list? Roughly: retail, finance, insurance, real estate, services, some agriculture — about 80 four-digit groups in total. If yes, general 1904.7 recording does not apply. Otherwise — continue.
State-plan deviations: a few state plans (Cal/OSHA, Michigan, others) have slightly different exemption lists. Use the federal Appendix A as the baseline and check your state's plan for deviations.
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5
General recording criteria — 1904.7(b)(3) through (b)(6)
At least one of: days away from work (1904.7(b)(3)), restricted work or job transfer (1904.7(b)(4)), medical treatment beyond first aid (1904.7(b)(5)), loss of consciousness (1904.7(b)(6)), or a significant injury or illness diagnosed by a physician or licensed healthcare professional. Any one match — recordable.
The first-aid line is where most disputes happen. The 1904.7(b)(5)(ii) exclusion list spells out what counts as “first aid only”: non-prescription medications at non-prescription strengths, simple bandages, ice or hot packs, drilling a fingernail to relieve pressure, eye patches, removing splinters with tweezers, etc. A prescription med, a stitch, finger-splinting, or removing a foreign object with anything beyond tweezers — that's medical treatment, and that's recordable.
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6
Hearing loss — 1904.10
A Standard Threshold Shift (STS) — a change of 10 dB or more from baseline averaged across 2,000 / 3,000 / 4,000 Hz in either ear — AND a current hearing level of 25 dB or more above audiometric zero (also averaged) in the same ear. Both conditions met — recordable as hearing loss in Column M(5).
Don't skip the second check: an STS alone, without the 25 dB threshold, requires a retest within 30 days but isn't recordable until the threshold is also reached.
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7
Tuberculosis — 1904.11
A positive TB skin or interferon-gamma release test after a known exposure to a person with active tuberculosis in the work environment is recordable. The exposure must be documented and work-environment-traceable.
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8
Needle-sticks, sharps, MSDs — 1904.8, 1904.12
Needle-stick injuries and cuts from sharp objects contaminated with another person's blood or other potentially infectious material are recordable under 1904.8 — the actual exposure event is the recordable item, not just a confirmed seroconversion. Musculoskeletal disorders (MSDs) are recordable when they meet any of the Step 5 general criteria; the 1904.12 paragraph captures specific MSD column treatment on the Form 300.
Form 300 column reference
Where the case lands once it's recordable.
Form 300 (the “Log of Work-Related Injuries and Illnesses”) carries one row per recordable case + a column-checkmark grid for the outcome and the illness/injury type. The combinations matter for the year-end Form 300A totals.
| Column | Heading | Tick when |
|---|---|---|
| Column G | Death | Affected person died of the work-related case or its complications. |
| Column H | Days away from work | Case resulted in at least one calendar day away from work. Per-case day count goes in Column K. |
| Column I | Job transfer or restriction | Case resulted in restricted-work activity or transfer to another job. Per-case day count goes in Column L. |
| Column J | Other recordable | Recordable case that doesn't meet H, I, or G — the “medical treatment beyond first aid / loss of consciousness / significant diagnosis” bucket. |
| Column M(1) | Injury | Cuts, fractures, strains, burns, sprains. The default illness/injury column. |
| Column M(2) | Skin disorder | Contact dermatitis, chemical-induced rash, occupational skin condition. |
| Column M(3) | Respiratory condition | Occupational asthma, silicosis, asbestosis, bronchitis from inhaled exposures. |
| Column M(4) | Poisoning | Systemic exposure to chemicals, heavy metals, gases. |
| Column M(5) | Hearing loss | STS plus the 25 dB threshold met (Step 6 above). |
| Column M(6) | All other illnesses | Cancers, infectious diseases, mental-health diagnoses, anything that doesn't fit M(2) – M(5). |
Common gotchas
Where EHS managers most often get it wrong.
Travel and off-site work
Hotel-room slip while on a business trip: generally not recordable (employee was engaged in normal-living activities). Slip in the conference-venue lobby on the way to a meeting: recordable (engaged in work). The 1904.5(b)(6) test is whether the employee was “engaged in work activities in the interest of the employer.”
Parking lots and company premises
Parking lots owned or controlled by the employer are part of the work environment — injuries there usually qualify. But the act of commuting (driving to or from work, even on company-controlled property) is generally not work-related under 1904.5(b)(2)(vii).
Pre-existing conditions made worse at work
A pre-existing condition aggravated by work is recordable if the work event significantly worsened it (more than the natural progression). Documentation from the treating clinician is the deciding artefact.
Self-administered medication
The medication classification — not who administers it — drives recordability. An employee who self-administers a prescription painkiller for a work-related strain still triggers Step 5's medical-treatment criterion. A non-prescription ibuprofen at OTC strength does not.
Mental-health diagnoses after a workplace event
Recordable when a physician or licensed healthcare professional links the diagnosis to a work-related event. You don't make the work-relatedness determination yourself — the clinician does, and you record what they document.
Walk through your case step by step.
The interactive walkthrough runs the same cascade as this page, but with your case in front of it. Answer one question at a time; each step shows the regulatory citation that pointed the result one way or the other. The final result is yours to print, save, or paste into your audit trail.
SE's compliance engine walks this exact cascade for every customer incident — with the citation trail attached, the per-state plan deviations applied, and the Form 300 column auto-filled. The free walkthrough above demonstrates the rule; the product carries the rule through claims, hazards, RCA, and the year-end Form 300A posting.
Need the next question after recordability? Where do I report this? walks the jurisdiction question across federal OSHA, 29 US state plans, NL Arbeidsinspectie, and UK HSE. After year-end, OSHA Rate Calculator rolls the recordable count up to TRIR + DART + the Form 300A summary you post on the wall. For chemical inventories, EPCRA Tier II checker answers whether you owe the annual filing.