OSHA Recordable vs. Reportable: The 1904 Decisions Safety Managers Miss

What's the difference between OSHA recordable and OSHA reportable?

Recordable and reportable are two separate obligations under 29 CFR 1904, and they run on different clocks to different audiences. Recording means entering a work-related injury or illness on the OSHA 300 Log, and the employer has 7 calendar days from learning of the case to make that entry. Reporting means calling or submitting a report directly to OSHA within a fixed number of hours, and it applies to only four outcomes: a fatality (8 hours), and an in-patient hospitalization, amputation, or loss of an eye (24 hours). A case can be recordable without being reportable, reportable without a completed 300 Log entry yet existing, or both at once. Treating the two as interchangeable is the single most common recordkeeping mistake safety managers make, and it shows up most often when a case looks minor on day one and turns reportable on day three.

Which injuries trigger a 1904 recording decision?

Under 29 CFR 1904.7, a case is recordable if it's work-related and results in any of: 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 licensed health care professional, even without those outcomes. First aid alone, as OSHA defines a specific list of first-aid measures, does not make a case recordable. The judgment call most teams get wrong is medical treatment versus first aid: a prescription-strength dose of an over-the-counter medication, sutures, or a follow-up X-ray that finds a fracture all cross into medical treatment, while an over-the-counter dose at the labeled strength, a tetanus shot, or a bandage stays first aid. The second common miss is restricted work: if a physician restricts an employee from performing even one routine job function, the case is recordable the day that restriction starts, not the day symptoms resolved.

OSHA recordable vs. reportable at a glance

Question	Recordable (1904.7)	Reportable (1904.39)
Who gets notified	Internal OSHA 300 Log only	OSHA directly, by phone or online
Clock	7 calendar days from employer awareness	8 hours (fatality) or 24 hours (hospitalization, amputation, eye loss)
Trigger	Death, days away, restricted work, medical treatment, loss of consciousness, significant diagnosis	Only 4 specific outcomes: death, in-patient hospitalization, amputation, loss of an eye
Employer size exemption	Partial exemption for 10 or fewer employees, and listed low-hazard industries	None; applies to all covered employers regardless of size
Can one case be both?	Yes	Yes

Does a small employer still have to report a hospitalization?

Yes. The 10-or-fewer-employee partial exemption under 1904.1 applies only to the routine recordkeeping requirement, meaning those employers don't have to maintain OSHA 300/300A/301 forms in a typical year. It does not touch 1904.39. Every employer covered by the OSH Act, regardless of size or industry, must call or report online within 8 hours of a fatality and within 24 hours of an in-patient hospitalization, amputation, or loss of an eye. The same split applies to the low-hazard industry list in Appendix A to Subpart B: exempt from routine logs, not exempt from the four reportable outcomes.

How does a hearing loss case get recorded under 1904.10?

Hearing loss runs its own two-part test instead of the general 1904.7 criteria. A case is recordable when an employee has a work-related standard threshold shift (STS), defined in 29 CFR 1910.95(g)(10)(i) as a 10 dB or greater average shift from baseline at 2000, 3000, and 4000 Hz in either ear, and that same ear's total hearing level is 25 dB or more above audiometric zero, averaged at those same three frequencies. Both conditions have to be true in the same ear for the same test. OSHA's 2002 clarification folded the age-correction option into the calculation, so an STS that would otherwise qualify can be adjusted for presbycusis using Appendix F tables before the 25 dB fence is checked. Hearing loss is never reportable under 1904.39 on its own; it has no path to a fatality, hospitalization, amputation, or eye-loss outcome, so it stays a recording question only.

How Foster handles this

Foster's audiometric testing runs the STS math on every annual test, not just the ones that look borderline, because the 10 dB shift plus 25 dB fence calculation in 1904.10 has to be checked against baseline every time, and a missed STS is the gap OSHA's compliance officers look for first in a hearing conservation file. Our hearing testing service flags a confirmed STS the day results come back, with the age-correction option applied before anyone decides whether a case is recordable. For employers tracking recordability decisions, retest deadlines, and 300 Log entries across more than one requirement or more than one site, Foster's Compliance Workspace product ties each employee's testing history to its CFR citation so the 7-day and 24-hour clocks don't get missed between testing cycles. See our audiogram record retention post for how long a recordable hearing loss case has to stay on file. Request a quote for a hearing conservation program review.

Frequently asked questions

Is a near-miss OSHA recordable?

No. A near-miss, by definition, involves no injury or illness, so it never reaches the 1904.7 recordability test. OSHA recordkeeping only applies once an actual work-related injury or illness has occurred; near-misses are a safety-management practice, not a 1904 obligation.

Does a reportable case always end up on the OSHA 300 Log?

Almost always, but the clocks don't line up. A fatality or hospitalization that meets 1904.39 gets reported within hours, while the same case still has up to 7 calendar days to appear on the 300 Log under 1904.29, so the report to OSHA typically happens before the log entry exists.

What counts as medical treatment instead of first aid?

29 CFR 1904.7(b)(5)(ii) lists first aid exhaustively: things like an over-the-counter medication at nonprescription strength, cleaning a wound, a butterfly bandage, or a single dose of a tetanus shot. Anything beyond that list, including prescription-strength medication, sutures, or a rigid immobilization device, is medical treatment and makes the case recordable.

If an employee misses one shift for a doctor visit, is that recordable?

Not automatically. A day away from work is recordable when the physician actually restricts the employee from working that day for the work-related condition. A voluntary absence to attend an appointment, without a work restriction, generally does not meet the days-away criterion on its own.

Sources

• 29 CFR 1904.7, General recording criteria (OSHA)
• 29 CFR 1904.39, Reporting fatalities, hospitalizations, amputations, and eye loss (OSHA)
• OSHA FAQ, 1904.10 recording criteria for hearing loss