OSHA Recordability FAQ
Answers to the most common questions about OSHA recordability determinations.
Q.Is going to the emergency room automatically OSHA recordable?
No. An ER visit alone does not make a case recordable. Recordability depends on what treatment was provided, not where it was provided. If an employee goes to the ER and receives only first aid (cleaning, bandaging, OTC medication at OTC strength, observation), the case is not recordable based on medical treatment. However, if the ER visit involves other recordability triggers — days away from work, loss of consciousness, prescription medication, sutures — then it is recordable.
Q.Are stitches (sutures) OSHA recordable?
Yes. Sutures, staples, and surgical glue are medical treatment beyond first aid. Only butterfly bandages and Steri-Strips qualify as first aid under 29 CFR 1904.7(b)(5)(ii). If stitches are used to close a wound, the case is recordable regardless of severity.
Q.Does a workers' compensation claim automatically make a case OSHA recordable?
No. Workers' compensation and OSHA recordkeeping are separate systems with different criteria. A workers' comp claim can be filed for a case that is not OSHA recordable, and an OSHA recordable case may not necessarily generate a workers' comp claim. You must evaluate each system independently.
Q.Is a prescription for ibuprofen OSHA recordable?
Yes — if ibuprofen is prescribed at a prescription-strength dose. Non-prescription medication taken at a nonprescription strength is first aid. However, if a physician prescribes ibuprofen (e.g., 800mg Rx strength), that constitutes medical treatment beyond first aid, making the case recordable. This is one of the most common recordability errors.
Q.Does a second opinion visit make a case recordable?
Not necessarily. A physician visit solely for observation or counseling — where no treatment is provided — does not make a case recordable. If the employee sought a second opinion and only received an evaluation with no treatment prescribed or administered, the case is not recordable based on that visit alone.
Q.Does a positive post-incident drug test make the case non-recordable?
No. A positive drug test may be relevant to the investigation, but it does not change whether the injury itself is work-related or meets recording criteria. If the injury otherwise meets recording criteria, it must be recorded. (Note: OSHA's anti-retaliation rule also prohibits using drug testing as a means to discourage injury reporting.)
Q.Is a sprain or strain OSHA recordable?
It depends on treatment and outcome. A sprain that is treated with only first aid (rest, ice, OTC medication at OTC strength, elastic wrap) and results in no days away from work, no restricted duty, and no job transfer is not recordable. But if the sprain results in any of those outcomes, or if treatment exceeds first aid (prescription medication, PT, rigid brace), it is recordable.
Q.Are X-rays, MRIs, or CT scans OSHA recordable?
No. Diagnostic procedures — including X-rays, CT scans, MRIs, and blood tests — are not considered medical treatment when used solely for diagnostic purposes. An employee can visit the ER, receive imaging, and be sent home with OTC medication without triggering recordability based on treatment alone.
Q.Is a needle injection (like a cortisone shot) OSHA recordable?
Yes. Injections involving prescription medications (such as corticosteroids) constitute medical treatment beyond first aid and make the case recordable.
Q.If a physician recommends medical treatment but the employee refuses it, is it recordable?
Yes. Under OSHA's rules, if a physician recommends medical treatment — even if the employee declines to follow that recommendation — the case is recordable. The recommendation alone establishes recordability.
Q.How long do I have to make a recordability determination?
You have 7 calendar days after receiving information that a recordable work-related injury or illness occurred to record it on the OSHA 300 Log. For work-related fatalities, you must report to OSHA within 8 hours. For in-patient hospitalizations, amputations, or loss of an eye, you must report within 24 hours.
Q.Do I need to record injuries that happen in the parking lot?
Generally yes, if it is company property and the employee was in the course of work. Parking lot injuries on employer-controlled property are typically considered work-related under 29 CFR 1904.5(b)(1). There are exceptions for employees commuting (not yet on the clock) or purely personal tasks performed on work premises.