Near Miss vs OSHA Recordable: How to Separate Learning Events From Log Cases
A near miss has no injury or illness, so it never goes on the OSHA 300 Log; track it in your safety program instead.
The answer up front
A near miss has no injury or illness, so it never goes on the OSHA 300 Log; track it in your safety program instead. If someone involved later develops symptoms and a recording criterion is met, that person's case is recorded like any other.
Good safety programs track near misses, but the OSHA log has specific recording criteria.
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).
Applying it to real cases
Record only work-related injuries and illnesses that meet OSHA recording criteria while tracking near misses separately. 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.
Coordinators tend to do the data entry and chase the facts, so a short list of what to ask for, and from whom, saves more time than any template.
Where teams go wrong
Teams add every near miss to the OSHA log because it feels safer.
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.
Situations that change the answer
- An event can start as a near miss investigation and later become recordable if an injury outcome appears.
- OSHA's first aid list is complete. A treatment that is not on it is medical treatment for recordkeeping, no matter who provides it.
A worked example
A load slips from a crane and lands where a rigger had been standing seconds earlier. No one is hurt, so it is a near miss: investigated and tracked, but not logged. Two days later the rigger reports back pain from jumping clear, and a physician prescribes physical therapy. That case goes on the log, linked to the near-miss investigation.
A checklist you can reuse
- Log near misses in the safety program, not on the 300.
- Check everyone involved for injuries.
- Open an OSHA case only when an injury or illness appears.
- Link the investigation to any case that follows.
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
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.
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.
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 1904.29: OSHA Forms 300, 300A, and 301Occupational 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.