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OSHA & regulation7 min read

What makes an injury OSHA recordable: the 1904 decision tree

A medical professional carefully wrapping a bandage around an injured person's hand.

Most arguments about whether something is an OSHA recordable injury are three arguments at once. One person is asking whether it happened at work, another whether the clinic did anything serious, a third is quietly worried about the site's TRIR.

29 CFR 1904 asks those three questions in a fixed order and closes the list at the two points where judgment would otherwise creep in. Run every case through that order and most of the argument goes away. What is left is documentation. Part 1904 is US federal law; the last section covers what applies instead at a Canadian site.

Injury or illness occurs Work- related? § 1904.5 New case? § 1904.6 Meets a criterion? § 1904.7 yes yes yes no no no Recordable Not recordable: any single "no" ends it
Three gates, in order. A case has to clear all of them; one "no" at any gate ends the analysis. Most disputes are about gate one.

The three gates every case has to pass

Under § 1904.4(a), you record a case only if all three are true: it is work-related (§ 1904.5), it is a new case (§ 1904.6), and it meets a general recording criterion in § 1904.7 or a specific-case rule in §§ 1904.8 to 1904.12 (needlesticks, tuberculosis, hearing loss, medical removal, musculoskeletal disorders). Fail a gate and it stays off the 300 Log.

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