OSHA 300 Log Classification Recordable vs First Aid Decision Tree

Why this matters

The single most common 1904 recordkeeping citation is misclassification: an injury that should have been logged as a recordable case was instead written off as first aid, often because the office manager applied a definition that does not match 29 CFR 1904.7. Under-recording suppresses your incidence rate, which can trigger an OSHA programmed inspection if discovered, and a willful-falsification citation under 29 CFR 1904.36 if the under-recording looks intentional. The good news is that the rule is mostly a clean decision tree. Walk it the same way every time and you will be right.

Step 1 - was the case work-related

29 CFR 1904.5 sets the work-relatedness test. An injury or illness is work-related if an event or exposure in the work environment either caused or contributed to the condition, or significantly aggravated a preexisting condition. Work environment means the establishment AND any other location where one or more employees are working or are present as a condition of employment.

If the injury happened off-site while the technician was on a service call, it is work-related. If it happened in the parking lot while the technician was clocked in and at the company shop, it is work-related (presumed in-the-course-of-employment).

Exceptions at 1904.5(b)(2) that knock the case OUT of work-related: present at work as member of general public (rare), symptom is solely the result of non-work activity that happens to surface at work, mental illness without supervisor concurrence in writing from a licensed health-care professional, common cold or flu, personal grooming, voluntary participation in wellness or recreation.

If not work-related, stop. Do not record.

Step 2 - is it a new case

Per 29 CFR 1904.6, a new case exists if the employee has not previously experienced a recorded injury of the same type to the same body part, OR they had recovered completely (no symptoms and back to full work) before the current incident. Recurrence of an old case is not a new case. Document the determination either way.

Step 3 - check the seven mandatory recordable triggers

Per 29 CFR 1904.7, ANY ONE of the following makes the case recordable on the 300 Log regardless of treatment given:

1. Death
2. Days away from work (one or more calendar days; count begins the day AFTER injury)
3. Restricted work or job transfer (the employee cannot do all routine duties)
4. Medical treatment beyond first aid (see Step 4)
5. Loss of consciousness
6. Significant injury or illness diagnosed by a physician or other licensed health-care professional (PLHCP) - includes any fracture, any cancer, chronic irreversible disease, punctured eardrum
7. Needlestick or sharp injury contaminated with another person's blood or OPIM

Trigger ONE and it is recordable. Treatment level does not override these.

Step 4 - the first-aid list at 1904.7(b)(5)(ii)

If none of the seven mandatory triggers fired, look at the medical treatment. 29 CFR 1904.7(b)(5)(ii) is an exhaustive, closed list of what counts as first aid. If the treatment is NOT on the list, it is medical treatment, which makes the case recordable.

First aid list (memorize for trade injuries):

• Non-prescription medications at non-prescription strength (advise vs prescribe is the test)
• Tetanus immunization (other vaccinations are medical treatment)
• Cleaning, flushing, or soaking wounds on the surface of the skin
• Wound coverings: bandages, gauze pads, butterfly bandages or Steri-Strips
• Hot or cold therapy
• Non-rigid means of support (elastic bandages, wraps, non-rigid back belts)
• Temporary immobilization devices used to transport (slings, splints, neck collars, back boards)
• Drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister
• Eye patches
• Removing foreign bodies from the eye with irrigation or cotton swab
• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means
• Finger guards
• Massages (physical therapy or chiropractic treatment are NOT first aid)
• Drinking fluids for heat stress relief

If treatment was given but it is NOT on this list (sutures, prescription medication, rigid splints, physical therapy, chiropractic manipulation, surgical glue, IV fluids), the case is recordable.

Common misclassifications to flag

• Prescription-strength NSAID for a back strain - recordable.
• ER visit for stitches even one stitch - recordable.
• Doctor recommends two days off but employee comes in anyway - still days-away-from-work case; record the days the doctor recommended.
• Restricted duty (cannot lift over 25 pounds) for one shift - recordable as restricted work case.
• Concussion with brief loss of consciousness on a fall - recordable for LOC alone even if released without further treatment.
• Punctured eardrum from a pressure-test incident with no other treatment - recordable as significant injury per 1904.7(b)(7).
• Heat exhaustion treated only with fluids and rest - NOT recordable IF no other triggers.

Privacy concerns at 1904.29(b)(7)

Certain cases (sexual assault, mental illness, HIV, hepatitis, tuberculosis, needlesticks contaminated with bloodborne pathogens, voluntary employee request for an injury to an intimate body part) are privacy concern cases. Record them on the 300 Log but enter Privacy Case instead of the employee's name. Maintain a separate confidential list cross-referencing case numbers to names.

Documentation that protects you

For every borderline case keep:

• The 301 incident report
• The PLHCP note describing treatment given
• Any restricted-duty or return-to-work paperwork
• Your written classification analysis (which trigger or first-aid item applied)

If you decline to record, the written analysis is your defense in a 1904 audit. If a compliance officer disagrees, they can issue a citation; your documentation lets you contest at informal conference.

References

• 29 CFR 1904.5 - Determination of work-relatedness
• 29 CFR 1904.6 - Determination of new cases
• 29 CFR 1904.7 - General recording criteria (recordable triggers and first-aid list)
• 29 CFR 1904.29 - Forms and privacy concern cases
• 29 CFR 1904.36 - Prohibition against discrimination and falsification
• OSHA Recordkeeping Handbook (OSHA Publication 3245)