HiTool – Recordkeeping

Stop. You are partially exempt (due to size) from keeping OSHA injury and illness records

unless informed by government to keep records under 29 CFR §1904.37, §1904.41, or §1904.42. If that happens, simply answer #1 as No and #2 as None of the Above to bypass #1 and #2. 

Stop. You are partially exempt (due to low-hazard industry) from keeping OSHA injury and illness records

unless informed by government to keep records under 29 CFR §1904.37, §1904.41, or §1904.42. If that happens, then simply answer #1 as No and #2 as None of the Above to bypass #1 and #2. 

Search for your NAICS code on census.gov/naics/ that corresponds to your primary business activity. 

or 

Contact HIOSH at (808) 586-9135 to learn what your NAICS code is

§1904.46(3) – An injury or illness is an abnormal condition or disorder. Injuries and illnesses include cases such as cuts, fractures, sprains, skin diseases, or respiratory conditions.

For OSHA recordkeeping purposes, an injury or illness can also consist of only subjective symptoms such as aches or pain.

Exposures that do not result in signs or symptoms are not considered injuries or illnesses and should therefore not be recorded on the OSHA forms.”

§1904.5(a) defines “Work-Related” as if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness.

Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception in §1904.5(b)(2) specifically applies.

§1904.5(b)(2)- You are not required to record injuries and illnesses if:

1. At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee.
2. The injury or illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside the work environment.
3. The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball.
4. The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption (whether bought on the employer’s premises or brought in). For example, if the employee is injured by choking on a sandwich while in the employer’s establishment, the case would not be considered work-related.
   Note: If the employee is made ill by ingesting food contaminated by workplace contaminants (such as lead), or gets food poisoning from food supplied by the employer, the case would be considered work-related.
5. The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee’s assigned working hours.
6. The injury or illness is solely the result of personal grooming, self medication for a non-work-related condition, or is intentionally self-inflicted.
7. The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work.
8. The illness is the common cold or flu.
   Note: contagious diseases such as tuberculosis, brucellosis, hepatitis A, or plague are considered work-related if the employee is infected at work.
9. The illness is a mental illness. Mental illness will not be considered work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related.

§1904.6(a) defines “New Case” as

• the employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body, or
• the employee previously experienced a recorded injury or illness of the same type that affected the same part of the body but had recovered completely (all signs and symptoms had disappeared) from the previous injury or illness and an event or exposure in the work environment caused the signs or symptoms to reappear.

STOP. Update the previously recorded injury/illness entry, if necessary.

§1904.7 requires a work-related injury/illness must be recorded if it results in one or more of the following:

• death;
• days away from work;
• restricted work or transfer to another job;
• medical treatment beyond first aid (see §1904.7(b)(5));
• loss of consciousness; or
• a significant injury/illness diagnosed by a physician or other licensed health care professional.

Note1: Medical Treatment does not include:

• Visits to a physician or other licensed health care professional solely for observation or counseling;
• The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils); or
• “First aid” as defined in paragraph (b)(5)(ii) of this section.

Note2: First aid means any of the [complete list] following : 

• Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
• Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
• Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
• Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
• Using hot or cold therapy;
• Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
• Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.).
• Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
• Using eye patches;
• Removing foreign bodies from the eye using only irrigation or a cotton swab;
• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
• Using finger guards;
• Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
• Drinking fluids for relief of heat stress.

STOP. Do not record the injury/illness

Record the injury/illness. 

• OSHA 300, 300A, 301 Forms (PDF)