Medical Removal Cases and OSHA Recordkeeping
When an employee is medically removed under the medical surveillance rules of an OSHA standard, such as lead or cadmium, the case must be recorded (29 CFR 1904.9).
Quick answer
When an employee is medically removed under the medical surveillance rules of an OSHA standard, such as lead or cadmium, the case must be recorded (29 CFR 1904.9). Record it as days away or restricted work, depending on how you comply with the removal, and check the poisoning column if a chemical exposure caused it.
Medical removal is easy to miss because it can sit outside normal injury intake.
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
Record medical removal cases when a specific OSHA standard requires recording. 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.
EHS managers usually run the monthly review, which is the best point to catch the late medical updates that change a case.
The mistake to avoid
Teams treat removal as an HR status change only.
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
- The underlying standard matters more than the label used by the workplace.
- Diagnostic work alone is not medical treatment. X-rays, blood tests, and observation visits do not make a case recordable by themselves.
Example
A battery plant worker's blood lead level reaches the removal level in the lead standard. The worker is moved to a lead-free job at full pay while levels come down. The case is recorded as restricted work (job transfer) in column I, with the poisoning column checked. A worker moved voluntarily before reaching the standard's removal level would not be recorded.
Step by step
- Identify the OSHA standard that required the removal.
- Record the case as days away or restricted work.
- Check the poisoning column for chemical exposures.
- Keep the surveillance results with the case.
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 1904.9: Medical removal recording criteriaOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]29 CFR 1904.7: General recording criteriaOccupational 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.