New Case vs Continuation of an Old Case on OSHA Logs
It is a new case if there is no prior recorded case of the same type on the same body part, or the employee fully recovered and work caused a recurrence.
Quick answer
It is a new case if there is no prior recorded case of the same type on the same body part, or the employee fully recovered and work caused a recurrence. Symptoms that continue from an old case without full recovery stay with the original entry.
Repeat pain after a prior injury is not automatically a new OSHA case.
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
Decide whether a new event or exposure occurred or whether the old case continued. 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.
As the safety manager you usually own the decision itself, so the most useful habit is writing down the fact each call rests on at the time you make it.
The mistake to avoid
Teams create duplicate cases when symptoms flare after return to work.
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 significant new exposure can make a new case appropriate.
- Diagnostic work alone is not medical treatment. X-rays, blood tests, and observation visits do not make a case recordable by themselves.
Example
An employee's recorded back strain from March never fully resolved; in June the pain worsens and the doctor adds physical therapy. That updates the March case. A different employee who fully recovered from a March strain and re-injured their back lifting in September gets a new case.
Step by step
- Find any prior recorded case for the same body part.
- Check whether the employee fully recovered.
- Look for a new workplace event or exposure.
- Add a new case or update the old one, with notes.
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 1904.5: Determination of work-relatednessOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.33: Retention and updatingOccupational 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.