Incident Investigation and Recordkeeping
Recordability under 29 CFR 1904
A case is recordable if it is work-related and results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a physician or other licensed health care professional. First aid - including a butterfly bandage, tetanus shot, non-prescription medication at non-prescription strength, hot/cold compresses, and simple wound cleaning - is not medical treatment. Sutures, prescription drugs, and physical therapy are medical treatment.
Maintain the OSHA 300 Log, the 301 incident report, and post the 300A annual summary from February 1 through April 30. Retain records for five years. Report to OSHA within 8 hours any work-related fatality, and within 24 hours any work-related in-patient hospitalization, amputation, or loss of an eye.
Investigation method
Secure and photograph the scene before cleanup, collect physical evidence, review documents and training records, and interview witnesses separately and promptly using open-ended questions. Move from what happened (timeline, events and causal factors) to why (5 Whys, fishbone, root cause analysis). Distinguish immediate causes (unsafe acts and conditions) from root causes (management system failures such as missing training, poor design, absent supervision). Corrective actions must address root causes and be tracked to closure.
Traps
- Mixing up the 8-hour fatality and 24-hour hospitalization clocks.
- Labeling stitches as first aid, or a prescription as first aid.
- Assuming a near-miss is recordable; it is not, but it should be investigated.
- Privacy concern cases are logged as a case number without the name.
- Blame-oriented investigations suppress reporting and destroy data quality.
Worked example
A worker lacerates a hand. Butterfly bandage and cleaning: first aid, not recordable. Three sutures: medical treatment, recordable on the 300 Log. If the physician restricts him to light duty for two days, record it as a restricted-work case, not days away.
Rule of thumb
Ask two questions in order: is it work-related, and did it meet one of the recordability criteria?