A complete breakdown of OSHA’s injury and illness recordkeeping requirements: when an incident is recordable, who makes the first-aid determination, and what your 300 log actually means for your EMR.

Recordkeeping looks like clerical work. It is not. The decisions an EHS manager makes about 29 CFR 1904, whether a given incident lands on the 300 log or not, are some of the highest-stakes calls in the entire safety program. Get them wrong in one direction, and you invite an OSHA citation and a willful-violation problem. Get them wrong in the other, and you inflate the very injury rates that decide whether OSHA targets you for inspection, whether you qualify to bid on work, and what you pay in workers’ comp premiums.

The rules are also more nuanced than they look, and the place they trip up even experienced professionals is the line between first aid and medical treatment. That single distinction accounts for a large share of your recordable count, and it does not work the way most people assume. This is the complete 2026 breakdown: who has to keep records, exactly when an incident is recordable, how the first-aid determination really works and who makes it, and what all of it means for your experience modification rate.

Who has to keep records?

The core recordkeeping obligation applies to most employers with more than 10 employees at any point during the previous calendar year. Two groups are partially exempt: employers that had 10 or fewer employees at all times in the prior year, and employers in specific low-hazard industries that OSHA designates by NAICS code. If you are partially exempt, you do not have to keep the routine 300, 301, and 300A records, but you are never exempt from reporting severe incidents, which we will come back to.

For everyone else, the job is to record every recordable work-related injury and illness, correctly and on time. Which raises the central question.

When is an incident recordable?

A case is recordable only if it satisfies all three of these conditions at once. If anyone is missing, it is not recordable.

1. It is work-related. Under 1904.5, an injury or illness is work-related if an event or exposure in the work environment either caused or contributed to it, or significantly aggravated a pre-existing condition. The work environment includes the establishment and other locations where employees work, as well as the equipment and materials they use. There is a specific list of exceptions, such as injuries occurring while the employee is present as a member of the general public, the common cold or flu, and voluntary wellness or recreational activities, but absent an exception, a work connection is presumed.

2. It is a new case. Under 1904.6, it is a new case if the employee has not previously experienced a recorded injury or illness of the same type affecting the same body part, or has fully recovered from a previous such case. A recurrence of an old injury is not a new recordable case; a genuinely new event is.

3. It meets at least one general recording criterion. Under 1904.7, the case must result in one or more of the following: death; days away from work; restricted work or job transfer; medical treatment beyond first aid; loss of consciousness; or a significant injury or illness diagnosed by a physician or other licensed health care professional. There are also specific recording criteria for certain conditions: needlestick and sharps injuries, standard threshold shifts in hearing, tuberculosis, and medical removal cases.

Most of those criteria are unambiguous. Death is death. Days away is days away. The one that generates the overwhelming majority of judgment calls and errors is medical treatment beyond first aid.

The first-aid line, and why it causes so much trouble

Here is the rule that everything turns on: OSHA defines first aid as a specific, closed list of treatments in 1904.7(b)(5)(ii). If the treatment provided falls within that list, it is first aid, and absent another recording criterion, the case is not recordable. If the treatment goes beyond that list, it is medical treatment, and the case is recordable. The regulation explicitly states that this is a complete list; no other procedures count as first aid.

The list, in plain terms, includes things like:

• Non-prescription medication taken at a non-prescription strength
• Tetanus immunizations
• Cleaning, flushing, or soaking surface wounds
• Wound coverings such as bandages, gauze pads, butterfly bandages, and Steri-Strips
• Hot or cold therapy
• Non-rigid means of support, such as elastic bandages, wraps, and non-rigid back belts
• Temporary immobilization devices used to transport an injured person, such as splints and slings
• Drilling a fingernail or toenail to relieve pressure, or draining a blister
• Eye patches, and removing foreign material from the eye with irrigation or a cotton swab
• Removing splinters or foreign material from areas other than the eye by simple means
• Finger guards
• Massages
• Drinking fluids for heat stress relief

Anything not on that list is medical treatment beyond first aid. And there are four rules around it that constantly catch people.

Prescription medication is always a medical treatment. If a prescription is recommended or used, the case is recordable, regardless of whether it is actually filled, even if it is for a single dose. Over-the-counter medication at non-prescription strength is first aid; the moment it becomes prescription strength, it crosses the line.

The provider’s job title does not matter. This is the rule most people get backwards. A treatment on the first-aid list is still first aid even if a physician administers it in an emergency room. And a treatment beyond the list is medical treatment, even if a coworker provides it in the break room. What determines recordability is the nature of the treatment, not the credentials of the person who delivered it. A doctor applying a bandage and recommending over-the-counter ibuprofen has provided first aid. The same doctor prescribing prescription-strength ibuprofen has provided medical treatment.

A doctor visit is not automatically recordable. Following directly from the rule above, sending an employee to a clinic does not, by itself, make a case recordable. If the clinician evaluates the worker and provides only first-aid-level treatment, it stays first aid. Recordability depends on what was done, not on whether a professional was seen.

Self-treatment usually does not count until it is recommended. Treatment an employee chooses on their own is generally not medical treatment for recordkeeping purposes. But the moment the employer or a health care professional directs or recommends that treatment, it counts. OSHA illustrated this with a worker who bought a rigid wrist brace on his own; the case became recordable only once a physician recommended he continue using it, because a rigid immobilization device is medical treatment.

One more criterion deserves emphasis because it is easy to miss: a significant injury or illness diagnosed by a physician or other licensed health care professional is recordable even if only first aid was provided. Conditions like a fractured or cracked bone, a punctured eardrum, cancer, or a chronic, irreversible illness are recordable on diagnosis, regardless of treatment.

Who actually makes the determination

The deck asked the question directly, and the answer surprised many people: the employer makes the recordability determination. Not the treating physician. Not the urgent-care clinic. Not the workers’ comp adjuster.

The clinician’s job is to treat the patient. Deciding whether the resulting case is OSHA-recordable is the employer’s legal responsibility and is made by applying the 1904 criteria to the nature of the treatment provided or recommended. A clinic can tell you what they did; they do not decide what goes on your 300 log. This is precisely why so many recordability errors happen at the handoff: a busy supervisor assumes the clinic visit settled it, or records the case because a doctor was involved, when the actual treatment was first-aid-level. The determination is yours to make, and to defend.

This is also why a coordinated occupational health relationship is so valuable. When the people providing and documenting care understand the 1904 first-aid line, the information you need to make an accurate, consistent, defensible determination arrives in a usable form, every time.

The forms and the deadlines

Three forms carry the system, and each has its own timing:

• The 300 Log is the running record of recordable cases for the year. You must enter each recordable case within seven calendar days of learning that it occurred, including the classification (death, days away, restricted or transferred, or other recordable) and case details.
• The 301 Incident Report is the individual case record, also due within seven calendar days.
• The 300A Summary rolls up the year’s totals. It must be certified by a company executive and posted in a conspicuous location from February 1 through April 30.

You must retain all three for five years following the year they cover, and update the 300 log during that period if you learn new information about a recorded case. Separately, employers that meet the size and industry thresholds must submit their data to OSHA electronically under 1904.41. The expanded rule, effective January 1, 2024, requires case-level 300 and 301 data from larger establishments in designated high-hazard industries.

And regardless of size or exemption status, every employer must report a work-related fatality within 8 hours, and an inpatient hospitalization, amputation, or loss of an eye within 24 hours.

What your 300 log actually means for your EMR

Here is the part that EHS managers often do not connect, and it is the reason recordability accuracy matters far beyond compliance. Your 300 log is the raw material for the injury rates that follow you everywhere.

Your Total Case Incident Rate and your DART rate, the Days Away, Restricted, or Transferred rate, are both calculated directly from the cases on your 300 log. Those rates feed OSHA’s Site-Specific Targeting program, which uses them to decide which establishments to inspect. They feed the prequalification screens that major clients and contractors use to decide who can bid. And the recordable claims behind them, especially the lost-time and restricted-duty cases, become the incurred losses that drive your Experience Modification Rate, which in turn multiplies your workers’ comp premium.

That means misclassification is costly in both directions. Record first-aid cases as recordable, the “just to be safe” habit, and you inflate your TRIR and DART, which can push you onto OSHA’s inspection list, knock you out of bids, and overstate your loss picture. Fail to record genuine recordable cases, and you have committed a recordkeeping violation that can be cited as willful, with penalties reaching into six figures per violation. Accurate first-aid determinations are not just a compliance nicety. They are simultaneously protecting your inspection profile, your eligibility to win work, and your premium.

It is worth being precise about one thing: a medical-only recordable case and a lost-time recordable case are very different animals for your EMR. In most states, a medical-only claim is reduced by 70% in the experience rating calculation, while a lost-time claim counts at full weight. So the same underlying injury can have a dramatically different cost depending on whether it is managed well enough to stay medical-only, which is decided clinically in the days after the injury, not in the recordkeeping office.

Where EHS managers go wrong

The common failure patterns are predictable, and every one of them is avoidable:

• Recording first-aid cases as recordable out of an abundance of caution, which inflates rates that have real consequences.
• Treating any doctor visit as automatically recordable when recordability depends on the treatment, not the visit.
• Missing the prescription-medication trigger, which makes a case recordable even when nothing else does.
• Overlooking significant diagnosis cases that are recordable on diagnosis, even with only first aid.
• Blowing the seven-day entry deadline or failing to update the log during the five-year retention period.
• Making inconsistent determinations across supervisors, shifts, or sites is itself a red flag in an audit.

How occupational health keeps the log accurate

Because the recordability determination hinges on the nature of the treatment provided or recommended, the quality of your 300 log is downstream of the quality and consistency of your injury care. That is where the right occupational health partner changes the picture.

HealthcareLive’s model puts qualified occupational medicine clinicians in front of injured workers immediately, through Remote Injury Care and On-Site Programs, and pairs that with recordkeeping support built around the 1904 framework. The practical effect is that first-aid versus medical-treatment calls are made correctly and consistently at the source, prescription and significant-diagnosis triggers are not missed, your employer determination is documented and defensible, and the data flowing into your 300 log, and therefore into your TRIR, DART, and EMR, is clean. Just as importantly, immediate clinical care keeps a larger share of injuries genuinely first-aid or medical-only, which lowers your recordable rates honestly, by changing outcomes rather than by miscounting.

The bottom line

Recordkeeping is where compliance and cost meet. The 300 log is not a filing exercise; it is the document that determines your injury rates, and those rates determine your inspection risk, your ability to win work, and your premium. The hardest and highest-leverage call in the whole system is the first-aid line, and it relies on the nature of the treatment, not the provider’s title, with the determination resting squarely with the employer. Get that line right, consistently and defensibly, and you protect your compliance and your cost at the same time. If you want the clinical and recordkeeping sides of that connected so your log is accurate at the source, HealthcareLive can help.

Frequently asked questions

What makes an injury OSHA recordable? An injury or illness is recordable only if it meets all three conditions: it is work-related, it is a new case, and it results in at least one general recording criterion, namely death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a licensed health care professional. There are also specific criteria for needlesticks, hearing loss, tuberculosis, and medical removal.

Is a doctor visit automatically recordable? No. Recordability depends on the treatment provided, not on whether a doctor was seen. If a clinician provides only first-aid-level treatment, the case is not recordable on that basis. A case becomes recordable when the treatment goes beyond OSHA’s closed list of first-aid procedures, for example, a prescription medication or sutures.

Does the person who provides treatment affect whether a case is recordable? No. OSHA is explicit that the provider’s professional status does not matter. A treatment on the first-aid list is first aid, even when a physician provides it, and a treatment beyond the list is medical treatment, even when a non-professional provides it. The nature of the treatment is what counts.

Who decides whether a case is recordable? The employer. The recordability determination is the employer’s legal responsibility and is made by applying the 1904 criteria to the treatment provided or recommended. The treating clinician treats the patient; they do not decide what goes on your 300 log.

Does prescription medication make a case recordable? Yes. A prescription medication is medical treatment beyond first aid, which makes the case recordable, regardless of whether the prescription is actually filled and even for a single dose. Over-the-counter medication at non-prescription strength, by contrast, is first aid.

What does my 300 log have to do with my EMR? A great deal. Your TRIR and DART rates are calculated from your 300 log, and the recordable claims behind them, especially lost-time cases, become the incurred losses that drive your Experience Modification Rate and therefore your premium. Inaccurate recording distorts these rates, which affects your inspection risk, your eligibility to bid on work, and your cost.

How long do I have to keep recordkeeping forms? You must retain the 300 log, the 301 incident reports, and the 300A summary for five years following the calendar year they cover, and update the 300 log during that period if you learn new information about a recorded case.

Sources and methodology

This article reflects current OSHA recordkeeping requirements under 29 CFR Part 1904 as published in the eCFR and on OSHA’s recordkeeping and 1904.7 pages, including the three-part recordability test (work-relatedness under 1904.5, new case under 1904.6, and the general recording criteria under 1904.7), the closed first-aid list in 1904.7(b)(5)(ii), OSHA’s interpretations that the provider’s professional status does not affect the first-aid determination and that prescription medication constitutes medical treatment, the significant-diagnosis criterion, the seven-day entry deadlines, the five-year retention requirement, the 300A certification and posting window, the electronic submission rule under 1904.41 effective January 1, 2024, and the severe-injury reporting requirements under 1904.39. Current explanatory guidance from ALL4, SmartQHSE, and Dakota Software (2026) informed the practical examples. The connection between 300 log data and experience rating reflects standard TRIR, DART, and EMR mechanics, as well as the 70% medical-only reduction used in most states.

Service descriptions attributed to HealthcareLive, including Remote Injury Care, On-Site Programs, and occupational health recordkeeping support, reflect HealthcareLive’s own service design and network experience. This content is informational and does not constitute legal advice; confirm specific obligations with OSHA, your state plan, or qualified counsel.