Recurrence in OSHA Recordkeeping: When to Update Instead of Add
Update the original entry when symptoms continue from an earlier case; add a new case only after full recovery and a new workplace event.
The short answer
Update the original entry when symptoms continue from an earlier case; add a new case only after full recovery and a new workplace event. For chronic occupational illnesses such as silicosis, record once, however often symptoms recur.
Recurrence decisions matter because duplicates distort rates.
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).
How it plays out on site
Update the existing case when symptoms are a continuation rather than a new work event. 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 common mistake
Teams create a fresh row whenever an employee returns to the clinic.
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
- New work exposure or a new diagnosis can change the answer.
- A recommendation counts even if the employee declines it: prescription medication that is prescribed but never filled still makes the case recordable.
Worked example
An employee with occupational asthma has a new attack after a solvent spill in the plant. Because the episode was caused by a workplace exposure, it is a new case. If the same employee had symptoms at home with no workplace trigger, the original case would stand and nothing new would be added.
Checklist
- Review how and when the old case closed.
- Check for a new event or exposure.
- Follow the provider's opinion if you asked for one.
- Update the existing row or add a new one, with a note.
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 1904.33: Retention and updatingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.5: Determination of work-relatednessOccupational 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.