Workers Compensation vs OSHA Recordkeeping: Why the Lists Do Not Match
Workers' comp claims and the OSHA log answer different questions, so the counts rarely match; record based on Part 1904, not on claim status.
Quick answer
Workers' comp claims and the OSHA log answer different questions, so the counts rarely match; record based on Part 1904, not on claim status. A denied claim can still be recordable, and an accepted medical-only claim may not be.
Finance teams get nervous when OSHA logs do not match claim counts, but the two are built for different purposes.
The rule in plain English
A case goes on the OSHA 300 Log when three things are true: it is work-related (29 CFR 1904.5), it is a new case (29 CFR 1904.6), and it meets at least one general recording criterion (29 CFR 1904.7). The criteria are 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 other licensed health care professional (cancer, a chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum). Special rules add needlesticks, medical removal, hearing loss, and tuberculosis (29 CFR 1904.8 to 1904.11).
What this looks like in practice
Use OSHA recordability criteria instead of workers' compensation acceptance to decide the log. Recordability answers change as medical facts arrive, so a case decided on day one without notes is hard to defend in January. The fix is to decide in order (work-relatedness, new case, criteria) and to write down the treatment and work-status facts each decision rests on, including medication strength.
HR leaders sit where recordkeeping meets policy: how employees report, how cases are discussed, and how discipline and incentives are designed.
The mistake to avoid
Teams often record every claim or remove denied claims without doing the OSHA analysis.
Each recordable case adds to the 300A totals and the TRIR; days-away and restricted cases also count toward DART. For establishments with 100 or more employees in Appendix B industries, each case also becomes a row in the ITA case data.
Edge cases worth checking
- A case can be compensable but not OSHA recordable, or recordable before the claim decision is final.
- Diagnostic work alone is not medical treatment. X-rays, blood tests, and observation visits do not make a case recordable by themselves.
Example
Finance counts 31 claims; the log has 21 cases. Eleven claims are not on the log: 9 were first-aid-only treatment and 2 were injuries at an off-site company softball game (not work-related under the recreation exception). One case is on the log with no claim at all, because the employee chose not to file. Each difference gets one line of explanation.
Step by step
- Keep the claim file and the OSHA decision separate.
- Decide recordability from the facts and Part 1904.
- Reconcile differences with a short note on each case.
- Do not remove a case because its claim was denied.
What to keep in the case file:
- What the provider recommended, in writing if possible, including medication strength
- Work status notes (full duty, restrictions, or days away) with dates
- The work-relatedness basis and any exception considered
- The date you learned of the case and the date it became recordable
Where 300log helps
300log records each case's outcome, day counts, and case type in the columns the OSHA 300 Log uses, shows OSHA's definitions (such as restricted work) while you classify, and recalculates the 300A whenever a case changes.
For a quick answer without an account, use the free recordability checker.
Frequently asked questions
Is prescription medication always recordable?
A recommendation to use prescription medication, or a nonprescription drug at prescription strength, is medical treatment. The exception is medication used solely for diagnosis, such as eye drops to dilate pupils.
Who decides recordability, the doctor or the employer?
The employer. Providers supply the medical facts and recommendations; the employer applies Part 1904 to those facts and records the case.
What if the facts change after we log the case?
Update the log. If a first-aid case later needs medical treatment, or a recordable case later results in days away, change the entry (29 CFR 1904.33(b)).
Is a clinic visit automatically recordable?
No. A visit for observation, counseling, or diagnostic tests is not medical treatment. The case is recordable only if a recording criterion is met, such as treatment beyond first aid or a work restriction.
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.7: General recording criteriaOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]29 CFR 1904.5: Determination of work-relatednessOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]OSHA detailed guidance for the injury and illness recordkeeping ruleOccupational Safety and Health Administration · osha.gov(opens in a new tab)
Written and reviewed by the 300log Editorial Team. Guidance, not legal advice: confirm edge cases with OSHA or counsel.