Is This OSHA Recordable? The 13 Injury Situations Safety Managers Get Wrong Most Often

An employee faints at work, falls, and hits their head. The hospital provides stitches.

Is the injury OSHA recordable?

If you have worked in safety long enough, you know experienced professionals can strongly disagree on recordkeeping decisions. OSHA recordkeeping appears straightforward in regulation, yet real workplace situations rarely match textbook examples.

Most recordkeeping errors happen because organizations memorize outcomes instead of understanding OSHA’s decision logic. This article walks through the injury scenarios safety managers debate most often and explains how OSHA expects employers to analyze them.

How OSHA Actually Determines Recordability

Every case must pass three tests.

1. Work-Relatedness

29 CFR 1904.5

An injury or illness is work-related if an event or exposure in the work environment caused or contributed to the condition or significantly aggravated a pre-existing condition.

Most disputes occur here.

2. New Case

29 CFR 1904.6

The incident must be a new injury or a work-related aggravation of an existing condition.

3. General Recording Criteria

29 CFR 1904.7

A case becomes recordable if it results in:

• Death

• Days away from work

• Restricted work or job transfer

• Medical treatment beyond first aid

• Loss of consciousness

• Significant diagnosis by a licensed healthcare professional

If any step fails, the case is not recordable.

The Injury Scenarios Safety Managers Debate Most Often

1. Employee Faints Due to a Personal Medical Condition and Hits Their Head

Short Answer: Usually NO.

Why:
If loss of consciousness results solely from a personal medical condition such as low blood sugar, a seizure disorder, or cardiac condition, OSHA considers the event non-work-related. Injuries resulting exclusively from that personal condition are also not work-related.

Common Mistake:
Assuming any injury occurring at work must automatically be recorded.

2. Injury During Lunch or Break Time

Short Answer: Usually YES (if on company premises).

Why:
OSHA considers employer-controlled property part of the work environment, even during breaks. A slip or fall in a breakroom or cafeteria typically remains work-related.

Being off the clock does not remove work-relatedness.

3. Employee Reinjures an Old Injury at Work

Short Answer: DEPENDS.

Why:
A pre-existing condition becomes recordable only if workplace activity significantly aggravates it. If symptoms recur without workplace contribution, it is not a new case.

Key Question:
Did work worsen the condition?

4. First Aid vs. Medical Treatment

Short Answer: Medical treatment makes it recordable.

OSHA provides a strict definition.

First Aid Examples

• Non-prescription medication at non-prescription strength

• Wound cleaning

• Bandages or butterfly closures

• Hot or cold therapy

Medical Treatment Examples

• Prescription medication

• Sutures or staples

• Physical therapy

• Rigid immobilization devices

Severity does not matter. OSHA’s classification does.

5. Restrictions That Don’t Actually Restrict the Job

Short Answer: NO, not recordable if the employee can perform all routine job functions normally.

Why:
OSHA defines restricted work as a situation where an employee cannot perform one or more routine job functions or cannot work a full workday they would otherwise have been scheduled to work.

If a physician issues restrictions but those limitations do not prevent the employee from performing any part of their normal job, then no restricted work has occurred.

Example:
A doctor writes “avoid heavy lifting,” but the employee’s regular job involves no lifting. The employee performs their full job exactly as usual.

This is not restricted work under OSHA.

Common Mistake:
Recording any written restriction automatically without evaluating whether job duties were actually limited.

6. Precautionary Restricted Duty

Short Answer: YES, if routine job functions are limited.

If restrictions prevent normal duties or reduce work hours, the case meets OSHA recording criteria regardless of whether restrictions were precautionary.

Intent does not matter. Functional limitation does.

7. Parking Lot Injuries: Two Very Different Outcomes

Parking lot cases cause significant confusion because two rules apply depending on what happened.

Scenario A: Slip, Trip, or Fall in Employer Parking Lot

Short Answer: YES, recordable if criteria are met.

Why:
Employer-controlled parking lots are part of the work environment under 29 CFR 1904.5. Injuries occurring while employees walk to or from work on company premises are work-related.

Examples:

• Ice slip

• Trip over curb

• Fall exiting vehicle

Scenario B: Employee Struck by a Moving Vehicle While Commuting

Short Answer: NO, not recordable.

Why:
OSHA distinguishes between premises conditions and motor vehicle accidents occurring during normal commuting. OSHA Letters of Interpretation clarify that injuries caused by motor vehicle accidents in company parking lots while employees are arriving or leaving work fall under the commuting exception and are not considered work-related.

The key distinction:

• Hazard created by workplace environment → work-related

• Normal commuting motor vehicle accident → not work-related

Common Mistake:
Treating all parking lot injuries the same.

8. Employee Injured While Working From Home

Short Answer: DEPENDS.

Only injuries directly related to performing work tasks are work-related.

Recordable:

• Tripping over work equipment during assigned duties.

Not recordable:

• Injuries from personal household activities.

Location alone does not determine recordability.

9. Injury During a Voluntary Wellness Activity

Short Answer: Usually NO.

Voluntary participation in recreational or wellness programs is generally excluded from work-relatedness unless participation is required or tied to job duties.

10. Employee Initially Refuses Treatment but Later Receives Medical Care

Short Answer: YES.

Recordability depends on the final outcome. Once medical treatment beyond first aid occurs for a work-related injury, the case becomes recordable regardless of initial refusal.

11. Contractor Injured at Your Facility

Short Answer: DEPENDS.

The employer providing day-to-day supervision records the injury.

Supervision, not location, determines responsibility.

12. Heat Illness or Cold Exposure

Short Answer: Usually YES.

Environmental exposure during work activities is considered work-related even if personal susceptibility contributes.

13. Injury Reported Days Later

Short Answer: YES, if evidence shows workplace causation.

Delayed reporting does not affect recordability obligations.

The 30-Second OSHA Recordable Test

Ask three questions:

1. Did the work environment cause or contribute to the condition?

2. Is this a new case or work-related aggravation?

3. Did it result in death, days away, restriction, medical treatment, loss of consciousness, or significant diagnosis?

If yes to all three, record it.

Why OSHA Recordkeeping Is Frequently Misunderstood

OSHA logs are often treated as safety report cards. They are not. Recordkeeping exists to identify injury trends, not assign blame or determine fault.

A recordable injury does not equal an OSHA violation, and failing to record legitimate cases creates greater regulatory exposure than recording them correctly.

Consistency and documented reasoning matter more than trying to achieve a low number.

Final Thought

The hardest OSHA recordkeeping decisions are rarely about the injury itself. They are about understanding how OSHA evaluates work-relatedness.

When you apply OSHA’s reasoning instead of memorizing examples, gray areas become manageable and defensible.

When uncertainty remains, document your analysis. A clearly reasoned decision grounded in OSHA logic is the strongest position an employer can take.