19.5 OSHA Injury and Illness Recordkeeping and Enforcement

CIH Certified Industrial Hygienist Exam

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1 Chapter 1: The CIH Exam and How to Use This Guide

1.1 CIH Exam Format, Scoring, and Test-Day Logistics 1.2 Eligibility, Application Windows, Fees, and Certification Maintenance 1.3 The BGC Blueprint, Subject Areas, and a Calculation-First Study Plan

2 Chapter 2: Basic Science & Calculations

2.1 Gas Laws and Vapor Calculations 2.2 Unit Conversions: ppm, mg/m³, and Standard Temperature/Pressure 2.3 Fluid Mechanics and Airflow Fundamentals

3 Chapter 3: Air Sampling & Instrumentation

3.1 Active and Passive Air Sampling Strategies 3.2 Particulate and Aerosol Sampling 3.3 Direct-Reading Instruments and Calibration

4 Chapter 4: Analytical Chemistry & Lab Methods

4.1 Gas Chromatography and Mass Spectrometry 4.2 High-Performance Liquid Chromatography and Ion Chromatography 4.3 Spectroscopy and Elemental Analysis 4.4 Gravimetric, Microscopy, and Wet Chemical Methods 4.5 Laboratory Quality Assurance, Chain of Custody, and Desorption Efficiency

5 Chapter 5: Biostatistics & Epidemiology

5.1 Lognormal Distributions and Exposure Data Statistics 5.2 Upper Confidence Limits (UCL95) and Compliance Decision Rules 5.3 Epidemiological Study Designs and Measures of Association 5.4 Sampling Strategy: Sample Size, Power, and Worker Selection

6 Chapter 6: Toxicology & Biological Monitoring

6.1 Dose-Response Relationships and Points of Departure 6.2 Toxicokinetics: Absorption, Distribution, Metabolism, and Elimination 6.3 Aerosol Deposition, Clearance, and Respiratory Tract Dosimetry 6.4 Hepatic, Renal, Neurologic, and Hematologic Target Organ Toxicity 6.5 Pulmonary Toxicology, Carcinogenicity, and Reproductive Hazards 6.6 OEL Frameworks, Classifications, and Excursion Limits 6.7 Chemical Mixtures and Extended Work-Shift OEL Adjustments 6.8 Biological Exposure Indices (BEIs) and Biomonitoring

7 Chapter 7: Biohazards & Indoor Environmental Quality

7.1 Mold, Fungi, and Microbial Contaminants 7.2 Infectious Agents, Bloodborne Pathogens, and Biosafety Levels 7.3 Indoor Environmental Quality (IEQ) Investigations 7.4 Sanitation, Potable Water, and Personal Hygiene Programs

8 Chapter 8: Community Exposure & Environmental Health

8.1 Clean Air Act Framework, NAAQS, and New Source Review 8.2 Hazardous Air Pollutants, CEMS, and EPA Reference Methods 8.3 Atmospheric Stability, Lapse Rates, and Plume Morphology 8.4 Gaussian Plume Modeling, Plume Rise, and Environmental Fate 8.5 HAZWOPER Scope, Mandates, and Training Tiers 8.6 Protection Levels, Site Zoning, Incident Command, and Decontamination 8.7 Water Pollution, Hazardous Waste, and Community Right-to-Know

9 Chapter 9: Health Risk Analysis & Hazard Communication

9.1 GHS Hazard Classification: Health and Physical Hazard Criteria 9.2 GHS Labels, Safety Data Sheets, and Trade Secret Rules 9.3 The AIHA Exposure Assessment Strategy and Similar Exposure Groups 9.4 Qualitative Exposure Profiling and the AIHA Risk Matrix 9.5 Quantitative Health Risk Characterization: HQ, HI, and ELCR 9.6 NIOSH Occupational Exposure Banding 9.7 Risk Communication and Reporting to Affected Parties

10 Chapter 10: Industrial Ventilation Principles & LEV Design

10.1 Elimination, Substitution, Isolation, Containment, and Process Change 10.2 LEV Hood Taxonomy and Capture Velocity Selection 10.3 Hood Airflow Equations, Entry Losses, and Hood Static Pressure 10.4 Particulate Transport Aerodynamics and Duct Sizing 10.5 Duct Friction, Fitting Losses, and System Balancing 10.6 Fan Categories and Pressure Dynamics Across the Fan 10.7 System Curves, the Fan Laws, and Density Corrections

11 Chapter 11: General Ventilation, Air Cleaning & Diagnostics

11.1 Dilution Ventilation Principles and Steady-State Modeling 11.2 Transient Purging and Air Distribution Geometry 11.3 Particulate Air Cleaning: Cyclones, Baghouses, Scrubbers, and ESPs 11.4 Gaseous Emission Control and Air Cleaner Selection 11.5 Ventilation System Troubleshooting and Testing

12 Chapter 12: Noise Measurement & Hearing Conservation

12.1 Acoustic Physics and Decibel Mathematics 12.2 Sound Propagation, Octave Bands, and Frequency Weighting 12.3 Noise Dose Metrics and OSHA versus ACGIH Criteria 12.4 Exchange Rates, Extended Shifts, and Dosimetry Field Protocols 12.5 Engineering Noise Controls and Hearing Protector Attenuation 12.6 Hearing Conservation Programs and Standard Threshold Shifts 12.7 Hand-Arm and Whole-Body Vibration

13 Chapter 13: Thermal Stress Assessment & Control

13.1 Wet Bulb Globe Temperature (WBGT) and Heat Stress Indices 13.2 Heat-Related Disorders, Acclimatization, and Work/Rest Regimens 13.3 Cold Stress Evaluation and Wind Chill

14 Chapter 14: Ionizing Radiation Protection

14.1 Ionizing Radiation Physics and Radioactive Decay Kinetics 14.2 Radiation Units, Radiobiology, and Health Effects 14.3 ALARA, Stay-Time, and the Inverse Square Law 14.4 Shielding Physics, Material Selection, and Gamma Constants 14.5 Radiation Detection Instruments and Spectrometry 14.6 Personnel Dosimetry, Dose Limits, and Contamination Surveys

15 Chapter 15: Non-Ionizing Radiation & Laser Safety

15.1 The Non-Ionizing Spectrum and Static/ELF Field Exposures 15.2 Radiofrequency and Microwave Exposure: SAR, Standards, and Surveys 15.3 Ultraviolet, Visible, and Infrared Radiation Hazards 15.4 Laser Safety Classifications and Optical Density Calculations 15.5 Illumination, Lighting Design, and Visual Performance

16 Chapter 16: Non-Engineering Controls & Personal Protective Equipment

16.1 Respiratory Protection Programs and Assigned Protection Factors 16.2 Maximum Use Concentration, Oxygen Deficiency, and Breathing Air 16.3 Particulate Filters, Sorbent Cartridges, and Change Schedules 16.4 Respirator Fit Testing Protocols 16.5 Chemical Protective Clothing and Dermal Exposure Control

17 Chapter 17: Ergonomics & Workstation Design

17.1 Soft-Tissue Biomechanics and WMSD Pathophysiology 17.2 Ergonomic Risk Factors and Their Interaction Effects 17.3 The Revised NIOSH Lifting Equation 17.4 RULA, REBA, the Strain Index, and the ACGIH HAL TLV 17.5 Anthropometry and Workstation Geometry 17.6 VDT Workstations, Hand Tool Design, and Administrative Ergonomics

18 Chapter 18: Work Environments & Industrial Processes

18.1 Welding Fume Emissions, Metal Fume Fever, and Cr(VI)/Manganese Toxicology 18.2 Foundry Operations and Hot Work Fire Prevention 18.3 Vapor Degreasing, Pickling, Electroplating, and Cyanide Baths 18.4 Spray Coatings, Isocyanates, and Semiconductor Manufacturing 18.5 Confined Spaces and High-Hazard Industrial Operations 18.6 Asbestos, Lead, and Silica: Regulated Substance Programs 18.7 Abrasive Blasting and Surface Preparation

19 Chapter 19: IH Program Management & Professional Ethics

19.1 The BGC Code of Ethics: Canons and Enforcement 19.2 Professional Liability, Standard of Care, and Expert Testimony 19.3 Occupational Health & Safety Management Systems (ISO 45001, ANSI Z10) 19.4 Exposure Records Access and Medical Surveillance 19.5 OSHA Injury and Illness Recordkeeping and Enforcement

19.5 OSHA Injury and Illness Recordkeeping and Enforcement

Key Takeaways Explain This Topic AI

A case is recordable on the OSHA 300 log when it is work-related and results in death, days away, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosis by a licensed health care professional.

The 14 statutory first-aid treatments listed at 29 CFR 1904.7(b)(5)(ii) are never "medical treatment" — this closed list, not clinical judgement, decides recordability.

Incidence rates are normalised to 200,000 hours (100 full-time workers for a year): rate = (cases × 200,000) / total hours worked.

Fatalities must be reported to OSHA within 8 hours; in-patient hospitalisation, amputation, or loss of an eye within 24 hours.

Last updated: August 2026

OSHA Injury and Illness Recordkeeping and Enforcement

Exposure and medical records document what happened to individual workers. The OSHA 300 log and the enforcement process govern what an employer must report to the government and how a citation is issued and contested. The two systems have different retention rules, different triggers, and different legal consequences.

1. OSHA Injury & Illness Recordkeeping (29 CFR Part 1904)

Under 29 CFR Part 1904 , covered employers must record work-related injuries, illnesses, and fatalities. Mastering Part 1904 forms, recordability criteria, and first-aid exemptions is one of the most heavily tested areas on the CIH examination. +-------------------------------------------------------------------------+

• | THE OSHA RECORDKEEPING FORMS |
• +-------------------------------------------------------------------------+
• | |
• | [ OSHA FORM 300 ] - Log of Work-Related Injuries and Illnesses |
• | - Case-by-case log: Employee name, job title, date of injury, |
• | location, description of injury/illness, categorization, |
• | and count of days away or on job transfer/restriction. |
• | - Must be entered within 7 CALENDAR DAYS of receiving notice. |
• | |
• | [ OSHA FORM 300A ] - Summary of Work-Related Injuries and Illnesses |
• | - Annual summary: Total cases, total lost workdays, total hours |
• | worked by all employees, and annual average headcount. |
• | - Certified by Highest-Ranking Company Executive (Owner, Officer). |
• | - Must be POSTED visibly from FEBRUARY 1 through APRIL 30. |
• | |
• | [ OSHA FORM 301 ] - Injury and Illness Incident Report |
• | - Detailed incident investigation report for each logged Form 300 case|
• | - Completed within 7 CALENDAR DAYS of receiving information. |
• | |
• | * Retention Mandate: All Form 300, 300A, and 301 records must be |
• | retained for 5 YEARS following the end of the calendar year covered.|
• +-------------------------------------------------------------------------+
• General Recordability Criteria (29 CFR 1904.7)

An injury or illness is recordable if it is work-related , is a new case , and meets one or more of the following general recording criteria:

Death;

Days Away from Work: Days the employee was unable to work. Day of injury is not counted. Counting starts the day after the incident and includes all calendar days (weekends, holidays, scheduled days off). The count is capped at 180 calendar days .

Restricted Work Activity or Job Transfer: The employer keeps the employee from performing one or more routine job functions (functions performed regularly at least once per week) or from working a full workday.

Medical Treatment Beyond First Aid: Any treatment administered by a physician or licensed healthcare professional (PLHCP) that is not included on the 14 first-aid exemptions.

Loss of Consciousness: Any loss of consciousness caused by a work-related event, regardless of duration.

Significant Diagnosed Injury or Illness: Work-related cases diagnosed by a PLHCP, including cancer, chronic irreversible diseases, fractured or cracked bones, and punctured eardrums.

Specific Recording Criteria

Work-Related Hearing Loss (1904.10): Recordable if an employee experiences a Standard Threshold Shift (STS) —defined as an average change of ≥ 10 dB at 2000, 3000, and 4000 Hz in either ear compared to the baseline audiogram— AND the employee's total hearing level is ≥ 25 dB from audiometric zero (averaged across 2000, 3000, and 4000 Hz in the same ear).

Medical Removal (1904.9): Any case where an employee is medically removed under the requirements of an OSHA health standard (e.g., lead blood level, cadmium, benzene).

Occupational Tuberculosis (1904.11): Any employee who tests positive for tuberculosis infection (PPD skin test or blood assay) following a known occupational exposure to active TB.

Needlestick / Sharps Injuries (1904.8): All work-related needlesticks and cuts from sharp objects contaminated with another person's blood or other potentially infectious materials (OPIM).

2. The 14 Statutory First-Aid Treatments (29 CFR 1904.7(b)(5)(ii))

OSHA provides an exhaustive list of 14 treatments considered "first aid." If a treatment does not appear on this list, it is legally classified as medical treatment beyond first aid .

# First-Aid Treatment (Exempt from Recording) Contrasting Medical Treatment (Recordable if Work-Related)

1 Using non-prescription medications at non-prescription (OTC) strength. Using non-prescription medications at prescription strength (e.g., Ibuprofen > 800 mg per dose), or any prescription medication.

2 Administering tetanus immunizations. Administering other vaccines/immunizations (e.g., Hepatitis B vaccine following exposure, rabies vaccine).

3 Cleaning, flushing, or soaking wounds on the skin surface. Wound debridement involving surgical removal of necrotic tissue.

4 Using wound coverings such as bandages, Band-Aids, gauze pads, butterfly bandages, or Steri-Strips. Using sutures (stitches), surgical staples, or surgical skin glue (Dermabond).

5 Using hot or cold therapy (ice packs, heating pads). Whirlpool therapy or advanced physical therapy requiring clinical rehabilitation protocols.

6 Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts. Using rigid immobilization devices or orthopedic braces with rigid stays.

7 Using temporary immobilization devices while transporting an accident victim (splints, slings, neck collars, backboards). Applying casts or splints for ongoing therapeutic fracture immobilization.

8 Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister. Surgical incision and drainage of deep tissue abscesses.

9 Using eye patches. Surgical interventions or prescription eye drops for corneal ulcers.

10 Removing foreign bodies from the eye using only irrigation or a cotton swab . Removing foreign material embedded in eye tissue using medical instruments or magnetic burrs.

11 Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means. Surgical removal of foreign bodies requiring local anesthesia and incision.

12 Using finger guards. Custom rigid orthopedic orthotics.

13 Using massages. Physical therapy or chiropractic manipulative treatment prescribed over multiple sessions.

14 Drinking fluids for relief of heat stress. Administering intravenous (IV) fluids for dehydration or heat exhaustion.

• 3. OSHA Enforcement, Inspection Hierarchy & Contest Workflow
• Mandatory Immediate Reporting to OSHA (29 CFR 1904.39)

Employers must report catastrophic workplace events directly to OSHA within strict timeframes:

Fatalities: Must be reported within 8 hours of learning of a work-related death.

Severe Injuries: Inpatient hospitalizations of one or more employees, amputations, or the loss of an eye must be reported within 24 hours .

OSHA Inspection Priorities

OSHA conducts inspections according to a strict statutory hierarchy:

Imminent Danger: Conditions where there is reasonable certainty that a danger exists that could cause death or serious physical harm immediately.

Fatalities and Catastrophes: Incidents resulting in death or hospitalization of multiple employees.

Worker Complaints and Referrals: Formal written employee complaints alleging unsafe conditions or imminent hazards.

Targeted / Programmed Inspections: High-hazard industries identified through Site-Specific Targeting (SST), National Emphasis Programs (NEPs, e.g., Combustible Dust, Silica, Heat), or Local Emphasis Programs (LEPs). +-------------------------------------------------------------------------+

• | OSHA INSPECTION & CITATION WORKFLOW |
• +-------------------------------------------------------------------------+
• | |
• | [ STEP 1: OPENING CONFERENCE ] |
• | - CSHO presents credentials; outlines scope and purpose |
• | - Worker representative invited to participate |
• | | |
• | v |
• | [ STEP 2: WALKAROUND INSPECTION ] |
• | - Industrial hygiene monitoring, noise surveys, physical inspection |
• | - Private, confidential employee interviews |
• | | |
• | v |
• | [ STEP 3: CLOSING CONFERENCE ] |
• | - CSHO discusses observed hazards, apparent violations, and abatement |
• | | |
• | v |
• | [ STEP 4: ISSUANCE OF CITATIONS & PENALTIES ] |
• | - Area Director issues formal citations specifying abatement dates |
• | | |
• | v (Within 15 WORKING DAYS) |
• | +---------------------------+---------------------------+ |
• | | | |
• | v v |
• | [ INFORMAL CONFERENCE ] [ FORMAL NOTICE OF CONTEST ]|
• | - Negotiate settlement, penalty - Filed with Area Director |
• | reduction, or abatement extension within 15 working days |
• | - Held with OSHA Area Director - Referred to OSHRC for |
• | independent litigation |
• +-------------------------------------------------------------------------+
• Citation Classifications

De Minimis: Violations having no direct or immediate relationship to safety or health. No citations or financial penalties are issued; documented in case notes.

Other-Than-Serious: Violations directly related to job safety/health that would probably not cause death or serious physical harm (e.g., failure to post OSHA poster, missing HazCom recordkeeping).

Serious: Substantial probability that death or serious physical harm could result from a condition which exists, and the employer knew or should have known with the exercise of reasonable diligence.

Willful: Violations committed with intentional disregard of, or plain indifference to, the requirements of the OSH Act and worker safety.

Repeated: A violation of any standard upon re-inspection where a substantially similar violation was previously cited within the past 5 years .

Failure to Abate: Failure to correct a previously cited violation after the abatement date has passed (subject to severe daily penalties for each day the violation continues).

The 15-Working-Day Contest Period & OSHRC

Upon receipt of an OSHA Citation and Notification of Penalty, the employer has exactly 15 working days (excluding weekends and federal holidays) to:

Pay the proposed penalties and correct the hazards by the specified abatement date;

Request an Informal Conference with the OSHA Area Director to negotiate settlement agreements, penalty reductions, or amended abatement dates; or

File a formal, written Notice of Contest to challenge the citations, penalties, or abatement dates. Contested cases are adjudicated independently by the Occupational Safety and Health Review Commission (OSHRC) , an independent quasi-judicial federal agency separate from the Department of Labor.

• 4. Worked Step-by-Step Compliance & Recordability Examples
• Worked Example 18.3.1: Complex OSHA Recordability & Lost Day Evaluation

Scenario: On Tuesday morning, an operator in a chemical packaging facility suffers a second-degree chemical burn to the forearm from a spilled corrosive cleaning mixture. The following sequence of events occurs:

Tuesday (Day of Injury): The worker visits the on-site clinic. The occupational health nurse irrigates the burn with sterile saline, applies a topical non-prescription antibiotic ointment, covers the wound with a sterile gauze pad, and gives the worker two 200 mg Ibuprofen tablets (400 mg total dose). The worker completes the remaining 4 hours of their Tuesday shift.

Wednesday: The worker visits an urgent care clinic because of persistent pain. The attending physician prescribes an 800 mg Ibuprofen tablet to be taken three times daily (prescription strength) and signs a work limitation order stating: "No use of right arm; no lifting over 5 lbs for 4 calendar days (Thursday through Sunday)."

Thursday & Friday: The worker reports to work and is assigned to temporary light-duty administrative data entry (routine job is chemical drum handling).

Saturday & Sunday: The facility is closed; the worker was not scheduled to work.

Monday: The physician clears the worker with no restrictions; the worker returns to chemical drum handling.

Recordability Analysis:

Is the injury work-related? Yes, it occurred on the employer's premises during work operations.

Did Tuesday's clinic visit trigger recordability? No. Saline flushing, non-prescription antibiotic ointment, gauze wound covering, and 400 mg OTC Ibuprofen are all exempt under the 14 first-aid categories (29 CFR 1904.7(b)(5)(ii)).

Did Wednesday's medical intervention trigger recordability? Yes, for two independent reasons:

Prescription medication at prescription strength (800 mg Ibuprofen) is medical treatment beyond first aid.

The physician issued a formal job restriction.

How many days must be recorded, and under what category on OSHA Form 300?

Category: Record as a Job Transfer or Restriction case (Column I on Form 300).

Day Counting Rule: Counting begins the day after the restriction was ordered (Thursday) and includes all calendar days regardless of whether the worker was scheduled to work.

Days of restriction: Thursday (Day 1), Friday (Day 2), Saturday (Day 3), Sunday (Day 4) = 4 calendar days.

Form 300 Entry: 0 Days Away from Work; 4 Days on Job Transfer/Restriction.

Worked Example 18.3.2: Occupational Hearing Loss Recordability (STS + 25 dB Rule)

Scenario: A punch press operator enrolled in a Hearing Conservation Program undergoes annual audiometric testing. The baseline and current annual audiogram thresholds for the right ear are recorded below:

Test Frequency Baseline Threshold Right Ear Annual Audiogram Right Ear Age Correction Factor Corrected Annual Threshold

• 2000 Hz 10 dB 25 dB -2 dB 23 dB
• 3000 Hz 15 dB 35 dB -3 dB 32 dB
• 4000 Hz 10 dB 30 dB -5 dB 25 dB

Determine whether this hearing shift meets the criteria for recording on OSHA Form 300 under 29 CFR 1904.10.

Solution Steps:

Step 1: Calculate Average Baseline Hearing Level (2000, 3000, 4000 Hz): Baseline Avg = 10 + 15 + 10 3 = 35 3 = 11.67 dB \text{Baseline Avg} = \frac{10 + 15 + 10}{3} = \frac{35}{3} = 11.67\,\text{dB} Baseline Avg = 3 10 + 15 + 10 ​ = 3 35 ​ = 11.67 dB

Step 2: Calculate Average Age-Corrected Current Hearing Level: Current Corrected Avg = 23 + 32 + 25 3 = 80 3 = 26.67 dB \text{Current Corrected Avg} = \frac{23 + 32 + 25}{3} = \frac{80}{3} = 26.67\,\text{dB} Current Corrected Avg = 3 23 + 32 + 25 ​ = 3 80 ​ = 26.67 dB

Step 3: Calculate the Shift (Standard Threshold Shift [STS]): Shift = 26.67 dB − 11.67 dB = 15.00 dB \text{Shift} = 26.67\,\text{dB} - 11.67\,\text{dB} = 15.00\,\text{dB} Shift = 26.67 dB − 11.67 dB = 15.00 dB

STS Check: The shift of 15.00 dB ≥ 10.0 dB, confirming an age-corrected Standard Threshold Shift (STS) in the right ear.

Step 4: Check Total Hearing Level Criterion (≥25 dB above audiometric zero):

Current age-corrected average hearing level = 26.67 dB.

Criterion Check: 26.67 dB ≥ 25.0 dB.

Conclusion: Because the shift exceeds an STS (≥ 10 dB) AND the overall hearing level exceeds 25 dB from audiometric zero, this case is recordable on OSHA Form 300 as an occupational hearing loss illness.