General Recording Criteria | Recordkeeping Guidelines

An injury or illness is recordable when it meets any of the following criteria:

• Death,

• Days away from work,

• Restricted work or transfer to another job,

• Medical treatment beyond first aid,

• Loss of consciousness, or

• A significant injury or illness diagnosed by a physician or HCP.

Although most cases are recorded because they meet one of these criteria, some cases may meet more than one as the case continues. For example, an injured worker may initially be sent home to recuperate (making the case recordable as a "days away" case) and then subsequently return to work on a restricted "light duty" basis.

Death

Record an injury or illness that results in an employee's death by entering a check mark on the OSHA 300 Log in the space for cases resulting in death. Additionally, you have to verbally report a work-related fatality to OSHA within eight hours.

Days Away From Work

When an injury or illness involves one or more days away from work, record the injury or illness on the OSHA 300 Log with a check mark in the space for cases involving days away and an entry of the number of calendar days away from work. If the employee is out for an extended period of time, enter an estimate of the days that the employee will be away, and update the day count when the actual number of days is known.

Note

Begin counting days away on the day after the injury occurred or the illness began.

When a physician or HCP recommends that the worker stay at home but the employee comes to work anyway, record these injuries and illnesses on the OSHA 300 Log using the check box for cases with days away from work and enter the number of calendar days away recommended by the physician/HCP. Days away must be recorded whether or not the injured or ill employee follows the physician/HCP's recommendation.

If the physician/HCP recommends that the employee return to work but he or she stays at home anyway, end the count of days away from work on the date the physician/HCP recommends that the employee return to work.

In cases where you receive recommendations from two or more physicians or HCPs, make a decision as to which recommendation is the most authoritative and record the case based on that recommendation. The employer is the ultimate recordkeeping decision-maker and must resolve the differences in opinion. You may turn to a third HCP for this purpose, or make the recordability decision yourself.

Weekends, Holidays, and Vacations

Count the number of calendar days the employee was unable to work as a result of the injury or illness, regardless of whether or not the employee was scheduled to work on those day(s). Weekend days, holidays, vacation days, or other days off are included in the total number of days recorded if the employee would not have been able to work on those days because of a work-related injury or illness.

If an employee is injured or becomes ill on a Friday and reports to work on a Monday, and was not scheduled to work on the weekend, you do not need to record the case unless you have received information from a physician or HCP indicating that the employee should not have worked, or should have performed only restricted work during the weekend. If so, record the injury or illness as a case with days away from work or restricted work and enter the day counts, as appropriate.

If an employee is injured or becomes ill on the day before scheduled time off such as a holiday, a planned vacation, or a temporary plant closing, the case should be recorded only if you receive information from a physician or HCP indicating that the employee should not have worked, or should have performed only restricted work, during the scheduled time off. If that is the case, record the injury or illness as a case with days away from work or restricted work, and enter the day counts, as appropriate.

Capping the Count

You are not required to keep track of the number of calendar days away from work if the injury or illness resulted in more than 180 calendar days away from work and/or days of job transfer or restriction. In such a case, "cap" the total days away by entering 180 (or 180+) in the total days away column of the OSHA 300 Log.

Retiring or Leaving the Company

If an employee leaves your company for some reason unrelated to the injury or illness, such as retirement, a plant closing, or to take another job, you can stop counting days away from work or days of restriction/job transfer.

However, when an employee leaves your company because of the injury or illness, estimate the total number of days away or days of restriction/job transfer the employee would have experienced if he or she had remained on your payroll and enter the day count on the OSHA 300 Log.

Cases Carried into the Next Year

If a case occurs in one year but results in days away during the next calendar year, record the injury or illness only once. Enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap.

Restricted Work or Job Transfer

According to the Bureau of Labor Statistics, the incidence of restricted work cases grew nearly 70 percent between 1994 through 2000, largely in an effort to encourage injured or ill employees to return to work as soon as possible.

The return-to-work programs increasingly being relied on by employers (often at the recommendation of their workers' compensation insurers) are designed to:

• Prevent aggravating the injury or illness,

• Allow recuperation,

• Rehabilitate employees more effectively,

• Reintegrate them back into the workplace more rapidly,

• Limit workers' compensation costs, and

• Retain productive workers.

Additionally, many employees want restricted work when it is available, and would rather return to work on a restricted basis over recuperating at home.

Decide if the Injury or Illness is Considered "Restricted Work"

Restricted work occurs when, as the result of a work-related injury or illness:

• You keep the employee from performing one or more of the routine functions of his or her job (work activities regularly performed at least once per week), or from working the full workday that he or she would otherwise have been scheduled to work; or

• A physician or HCP recommends that the employee not perform one or more of the routine functions of his or her job, or not work the full workday that he or she would otherwise have been scheduled to work.

When an employee's injury or illness involves restricted work or job transfer but does not involve days away from work, record it on the OSHA 300 Log by checking the space for job transfer or restriction and enter the number of restricted or transferred days in the "restricted workdays" column. However, you do not have to record restricted work or job transfers if the restriction or transfer occurs only for the day on which the injury occurred or the illness began.

Recording Restricted Work Cases

When a physician or HCP recommends restricted work, record it only if it affects one or more of the employee's routine job functions. To determine whether this is the case, evaluate the restriction in light of the routine functions of the injured or ill employee's job. If the restriction from you or the physician/HCP keeps the employee from performing one or more of his or her routine job functions, or from working the full workday the employee would otherwise have worked, the employee's work has been restricted and you must record the case.

If an employee works only for a partial work shift because of a work-related injury or illness, record it as a day of job transfer or restriction, except for the day on which the injury occurred or the illness began.

If a physician/HCP recommends vague restrictions, such as that the employee engage only in "light duty" or "take it easy for a week," you should ask that person whether the employee can do all of his or her routine job functions and work all of his or her normally assigned work shift. If the answer to both of these questions is yes, then the case does not involve a work restriction and does not have to be recorded as such. However, if the answer to one or both of these questions is no, the case involves restricted work and must be recorded as a restricted work case. In cases where you are unable to get clarification from the physician/HCP who recommended the restriction, record the injury or illness as a case involving restricted work.

When a physician/HCP recommends a job restriction meeting OSHA's definition, but the employee does all of his or her routine job functions anyway, you still must record the injury or illness on the OSHA 300 Log as a restricted work case. If job restrictions are recommended, ensure that the employee complies with that restriction. If you receive recommendations from two or more physicians/HCPs, decide which recommendation is the most authoritative, and record the case based on that recommendation.

Recording Job Transfers

If you assign an injured or ill employee to a job other than his or her regular job for part of the day, the case involves transfer to another job. Both job transfer and restricted work cases are recorded in the same box on the OSHA 300 Log. Do not include the day on which the injury or illness occurred.

For example, if you assign, or a physician/HCP recommends that you assign, an injured or ill worker to his or her routine job duties for part of the day and to another job for the rest of the day, the injury or illness involves a job transfer.

You count days of job transfer or restriction in the same way you count days away from work. The only difference is that, if you permanently assign the injured or ill employee to a job that has been modified or permanently changed in a manner that eliminates the routine functions the employee was restricted from performing, you may stop the day count when the modification or change is made permanent. In these cases, count at least one day of restricted work or job transfer.

Medical Treatment Beyond First Aid

First aid and medical treatment criteria will probably be the criteria you use the most when deciding whether a work-related injury must be recorded. OSHA's list of first aid treatments is inclusive, that is, you can look at it and without elaborate analysis, determine whether a treatment is first aid and thus not recordable. These treatments are considered first aid whether they are provided by a lay person, a physician, or HCP. Any treatment not on the first aid list is considered medical treatment and recordable, even when it is provided by someone other than a physician or HCP.

If a work-related injury or illness results in medical treatment beyond first aid, record it on the OSHA 300 Log. If the injury or illness does not involve death, one or more days away from work, one or more days of restricted work, or one or more days of job transfer, enter a check mark in the box for cases where the employee received medical treatment but remained at work and was not transferred or restricted.

Loss of Consciousness

Every work-related injury or illness case involving a complete loss of consciousness (not merely a sense of disorientation or other diminished level of awareness) is recordable, regardless of the length of time the employee remains unconscious. Fainting episodes involving voluntary activities such as vaccination programs or blood donations are not recordable. However, fainting episodes that result from mandatory medical procedures such as blood tests or physicals required by OSHA standards are considered work-related events and, as such, are recordable if they meet one or more of the recording criteria.

What Makes an Injury or Illness "Significant"

Significant diagnosed work-related injuries or illnesses are recordable under the general criteria, even if they do not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness. However, there are significant injuries, such as a punctured eardrum or a fractured toe or rib, for which neither medical treatment nor work restrictions may be recommended. In addition, there are some significant progressive diseases, such as byssinosis, silicosis, and some types of cancer, for which medical treatment or work restrictions may not be recommended at the time of diagnosis but are likely to be recommended as the disease progresses.

OSHA believes that cancer, chronic irreversible diseases, fractured or cracked bones, and punctured eardrums are generally considered significant injuries and illnesses and must be recorded at the initial diagnosis, even if medical treatment or work restrictions are not recommended or are postponed in a particular case. Record these "significant" cases within seven days of receiving a diagnosis from a physician or HCP.