Respiratory Illness on OSHA Logs: When Exposure Becomes Recordable

A respiratory illness is recordable when workplace exposure caused or significantly aggravated it and a criterion, such as prescribed medication, is met. Colds and flu are excepted; other contagious diseases are recorded if the employee was infected at work.

Respiratory cases need careful source analysis because work and community exposures can overlap.

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).

Record when work exposure causes or significantly aggravates an illness and recording criteria are met. 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.

In healthcare, clinical follow-up and recordkeeping run in parallel, so build the link between employee health and the OSHA log into intake itself.

Teams sometimes record every positive test without a work-relatedness decision.

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.

• Alternative exposure evidence can change the conclusion.
• Diagnostic work alone is not medical treatment. X-rays, blood tests, and observation visits do not make a case recordable by themselves.

Two sanders at a furniture plant develop wheezing after a change in finishing products. Air sampling shows elevated exposure at their station, and both are prescribed inhalers. The cases are work-related and recordable, checked in the respiratory condition column. A coworker with the flu the same week is not recorded.

1. Collect the exposure history and work tasks.
2. Weigh workplace and community exposure evidence.
3. Check the diagnosis and treatment against the criteria.
4. Record in the respiratory condition column when recordable.

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

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.

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