The recordable incident rate OSHA requires from employers seems straightforward until you face a real situation on a jobsite. A worker gets two stitches -- recordable? A prescription for extra-strength ibuprofen -- recordable? A temp worker with a sprained wrist -- whose log does it go on?

These questions come up every week on active construction projects. Below are 25 of the most common, answered with specific OSHA regulatory citations so you can make defensible recording decisions.

Recording Criteria Questions

1. What exactly makes an incident "recordable" under OSHA?

An incident is recordable if it is work-related and results in any of the following: 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 healthcare professional.

The controlling regulation is 29 CFR 1904.7. The key threshold for most construction incidents is whether the treatment provided goes beyond OSHA's specific first aid definition in 1904.7(a).

2. Is stitches recordable?

Yes. Sutures (stitches), staples, and surgical wound closure are explicitly classified as medical treatment beyond first aid. Any wound that receives stitches produces a recordable case regardless of severity, location, or number of stitches. Even a single stitch on a minor laceration is recordable.

Butterfly bandages and Steri-Strips are classified as first aid and are not recordable when used as the sole treatment.

3. Is a prescription recordable?

Yes. Any prescription medication makes the case recordable, including prescription-strength versions of over-the-counter drugs. If a doctor prescribes ibuprofen 800mg, the case is recordable even though ibuprofen is available OTC at lower strengths.

The one exception: a single dose of prescription medication administered for diagnostic purposes (not treatment) does not trigger recording.

4. Are eye injuries recordable?

It depends on treatment. Flushing the eye with water or saline is first aid. Removing a foreign body from the surface of the eye with a cotton swab or irrigation is first aid. But removing a foreign body from the eye by a physician using instruments such as tweezers or a needle constitutes medical treatment and is recordable.

5. Is a tetanus shot recordable?

No. OSHA explicitly lists tetanus immunizations as first aid in 29 CFR 1904.7(a). A tetanus shot alone, even administered at a hospital, does not make the case recordable. However, if the worker also receives stitches or a prescription during the same visit, those treatments make it recordable regardless of the tetanus shot.

6. When is a sprain or strain recordable?

A sprain or strain is recordable when the treatment goes beyond first aid. Applying an elastic bandage, using hot or cold therapy, or recommending OTC medication is first aid. If the doctor prescribes medication, orders physical therapy beyond an initial evaluation visit, or restricts the worker's duties, the case becomes recordable.

7. Are diagnostic tests like X-rays recordable?

No. Diagnostic procedures alone (X-rays, MRIs, blood tests, CT scans) are not medical treatment. They are observation and evaluation. If the only actions taken are diagnostic and the worker returns to full duty with no prescription, the case is not recordable. But if the diagnostic test reveals a fracture and the doctor provides a splint, both the diagnosis and the splint treatment together make it recordable.

Pre-Existing Conditions and Special Cases

8. What about pre-existing conditions aggravated at work?

If a work event or exposure significantly aggravates a pre-existing condition, the aggravation is recordable. The test is whether the aggravation results in death, days away, restriction, transfer, or medical treatment beyond first aid. A carpenter with chronic back pain who lifts a heavy beam and experiences an acute flare-up requiring prescription muscle relaxants has a recordable case.

9. Is a heart attack on a construction site recordable?

Work-relatedness depends on whether the work environment contributed to the cardiac event. If the heart attack occurs during normal work activities and there is no evidence that the work environment did not contribute, the case is presumed work-related under the geographic presumption in 29 CFR 1904.5. The employer may rebut this presumption with evidence (such as a pre-existing cardiac condition with no work-related trigger).

10. Are mental health conditions recordable?

Mental health conditions are recordable only if they are work-related and diagnosed by a physician or licensed healthcare professional. Work-related PTSD following a workplace accident that requires treatment beyond first aid is recordable. General stress from workload is typically not recordable because it does not arise from a specific event or exposure in the work environment.

11. Is hearing loss recordable?

OSHA has specific criteria for recording hearing loss in 29 CFR 1904.10. A hearing loss case is recordable when an audiometric test shows a standard threshold shift (STS) of an average of 10 dB or more in either ear at 2000, 3000, and 4000 Hz AND the employee's total hearing level is 25 dB or more above audiometric zero in the same ear. The shift must be work-related.

Temporary Workers and Multi-Employer Questions

12. How do you handle incidents for temporary workers?

The employer who supervises the temp worker's day-to-day activities records the incident on their OSHA 300 log. In construction, this is usually the sub who directs the temp worker's tasks, not the staffing agency. OSHA issued a memo in 2015 clarifying that the host employer (the company directing the work) must record temp worker injuries.

Both the host employer and the staffing agency should coordinate on incident reporting. The hours worked by temp workers under your supervision also go into your hours-worked denominator.

13. Whose OSHA log captures an incident on a multi-employer site?

The employer of the injured worker records the incident on their own OSHA 300 log. If a plumbing subcontractor's employee is injured, the incident goes on the plumber's log, not the GC's log or another sub's log. This is true even if the hazard was created by a different employer on the site.

14. Does a GC include subcontractor incidents in their TRIR?

No. A GC's TRIR includes only incidents involving the GC's direct employees. Subcontractor incidents go on each sub's individual TRIR. However, GCs track and monitor sub TRIR data through prequalification and project-level safety reporting. Some owners calculate a project-wide incident rate that aggregates all employers, but this is a separate metric from any individual company's TRIR.

15. What if a temporary worker is injured during safety orientation?

If the temp worker is under your supervisory control during orientation (which they typically are), the incident goes on your 300 log. The hours spent in orientation count as hours worked in your denominator.

Calculation and Reporting Questions

16. What is the 200,000 multiplier in the TRIR formula?

The 200,000 represents the approximate number of hours 100 full-time employees work in one year (100 employees x 40 hours/week x 50 weeks). This normalizes the rate so companies of different sizes can be compared directly. A TRIR of 2.0 means 2 recordable incidents per 100 full-time-equivalent employees per year.

17. How do I calculate TRIR for my first year in business?

Use whatever months of data you have. If you started operations in July and are calculating your rate through December, use the incidents and hours from that 6-month period. The formula works the same regardless of the time period. Some prequalification forms will accept partial-year data for companies under 3 years old.

18. Can my TRIR be zero?

Yes. A TRIR of zero means no recordable incidents occurred during the reporting period. This is common for small companies (under 20 employees) with short reporting periods. For larger companies or longer periods, a zero TRIR becomes statistically less likely and may prompt GCs to verify recording accuracy.

19. How is TRIR different from DART rate?

TRIR counts all OSHA recordable incidents. DART counts only the subset that involved days away from work, restricted duty, or job transfer. DART excludes cases that were recordable solely because they involved medical treatment beyond first aid with no work restrictions. DART is always equal to or lower than TRIR.

20. Does OSHA have a required TRIR threshold?

No. OSHA does not set a maximum acceptable TRIR. The recording and reporting requirements apply to all employers regardless of their incident rate. However, OSHA does use industry-average incident rates to target employers for programmed inspections under the Site-Specific Targeting (SST) program. Establishments with rates significantly above the national average are more likely to be selected for inspection.

Specific Scenario Questions

21. A worker cuts their hand and drives themselves to urgent care. Is this recordable?

The act of going to urgent care does not determine recordability. What matters is the treatment received. If urgent care applies a bandage and administers OTC pain medication, it is first aid. If urgent care provides stitches or a prescription, it is recordable. The severity of the treatment, not the venue, determines the classification.

22. A worker reports a back injury at the end of their shift but cannot identify when it happened. Is this recordable?

If the injury is work-related (it arose from events or exposures in the work environment) and meets recording criteria, it is recordable. The worker does not need to identify the exact moment of injury. Cumulative trauma injuries that develop over a work shift are work-related if the work environment contributed to the condition.

23. A worker is injured on the way to work. Is this recordable?

Generally, no. Injuries occurring during the normal commute are not considered work-related under the geographic presumption. Exceptions exist if the worker was performing a work task during the commute (transporting materials, stopping at a jobsite), if the employer provides the transportation, or if the injury occurs in the employer's parking lot.

24. Can I remove a case from the 300 log if the worker's condition improves?

No. Once a case meets recording criteria, it remains on the 300 log for 5 years. You may update the case details (for example, changing the number of days away from work as the count finalizes), but you cannot delete the entry because the worker recovered. The only basis for removing an entry is a determination that the case was erroneously recorded (it was never actually recordable).

25. What if a worker refuses treatment that would make the case recordable?

Recordability is based on treatment actually received, not treatment that was recommended or available. If a worker suffers a laceration that a doctor recommends closing with stitches, but the worker declines and only receives bandaging, the case is classified as first aid based on the treatment received. However, if the underlying injury independently meets recording criteria (loss of consciousness, fracture, significant diagnosis), refusal of treatment does not change the classification.

Quick Reference: Common Construction Injuries and Recordability

Scenario	Recordable?	Reason
Laceration treated with bandage only	No	First aid
Laceration requiring stitches	Yes	Medical treatment
Sprained ankle wrapped with elastic bandage	No	First aid (elastic bandage = first aid)
Sprained ankle with prescription anti-inflammatory	Yes	Prescription = medical treatment
Dust in eye flushed with saline	No	First aid
Foreign object removed from eye with needle	Yes	Medical treatment
Bee sting treated with cold pack	No	First aid
Bee sting with anaphylaxis requiring epinephrine	Yes	Medical treatment (prescription auto-injector)
Sunburn treated with OTC aloe	No	First aid
Heat exhaustion with IV fluids administered	Yes	Medical treatment
Bruised finger with no treatment	No	No treatment threshold met
Fractured finger set with rigid cast	Yes	Medical treatment + significant diagnosis
Back strain with 2 days of restricted duty	Yes	Restricted work
Back strain treated with hot/cold therapy only	No	First aid

FAQs

How long do I need to keep OSHA 300 logs? Five years from the end of the calendar year they cover. During that 5-year period, you must update the logs to reflect any changes in case classification or days-away/restricted-duty counts. After 5 years, there is no OSHA requirement to retain the logs, though many GCs require subs to provide 3 years of data for prequalification.

Can OSHA fine me for not recording a recordable incident? Yes. Failure to record a recordable injury or illness violates 29 CFR 1904.29. OSHA can issue citations with penalties up to $16,131 per violation for other-than-serious or serious violations, and up to $163,939 for willful or repeat violations (2026 penalty amounts). Each unrecorded case is a separate violation.

Who is responsible for making the recording decision? The employer is responsible. In practice, this means the safety manager or designated recordkeeping person at the company. Field supervisors often make initial assessments, but the final recording decision should rest with someone trained in OSHA recordkeeping criteria. First-report documentation from the medical provider is essential for accurate classification.

Does workers' comp status affect OSHA recording? No. OSHA recording and workers' compensation are independent systems. A case can be recordable under OSHA but denied by workers' comp, or accepted by workers' comp but not recordable under OSHA. Workers' comp acceptance does not make a case OSHA recordable, and workers' comp denial does not make it non-recordable. Evaluate each system's criteria independently.

What if a subcontractor disagrees with my recording classification? As a GC, you do not control what goes on a subcontractor's OSHA 300 log. If you believe a sub is under-recording, you can flag the concern during project safety meetings, require additional documentation, and note the discrepancy in your prequalification records. Ultimately, each employer is responsible for their own recordkeeping. Persistent under-recording is a red flag for future prequalification decisions.

How do I report a workplace fatality to OSHA? Workplace fatalities must be reported to OSHA within 8 hours of the employer learning about the death. In-patient hospitalizations, amputations, and losses of an eye must be reported within 24 hours. Reports can be made by calling the nearest OSHA area office, calling the OSHA 24-hour hotline at 1-800-321-OSHA (6742), or submitting online through OSHA's reporting website.

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