OSHA recordkeeping for the ASP exam

Last checked October 26, 2026 against BCSP's ASP11 blueprint (V.2024.04.24) and the eCFR text of 29 CFR 1904 current as of October 22, 2026.

In short

• Where it sits on the ASP: the BCSP® ASP outline doesn't name 29 CFR 1904, but three tasks lean on it: calculating lagging indicators such as incidence rates and lost time (Domain 1, task 8), interpreting leading and lagging indicators (Domain 2, task 11), and understanding reporting and records control, including retention and worker privacy (Domain 9, tasks 1 and 4).
• The core test: record a case only if it is work-related, is a new case, and meets a general recording criterion or one of the specific-case rules (29 CFR 1904.4).
• The numbers to memorize: 7 calendar days to log a case, 8 hours to report a fatality, 24 hours to report an in-patient hospitalization, amputation or loss of an eye, 5 years to keep the records, and February 1 to April 30 for posting the annual summary.
• The math: incidence rate = cases × 200,000 ÷ hours worked. DART uses only the days-away and restricted or transferred cases.

BCSP's ASP reference list says candidates are "strongly advised to become familiar with industry regulations, standards, and practices," and recordkeeping is the federal rule behind most lagging-indicator questions. This page is a study sheet, not compliance advice. State Plan states can have their own rules.

Step 1: is the case recordable?

29 CFR 1904.4 sets three tests. All three must be yes.

1. Work-related. An event or exposure in the work environment caused or contributed to the condition, or significantly aggravated a pre-existing one. OSHA presumes work-relatedness for events in the work environment unless one of the exceptions in 1904.5(b)(2) applies.
2. New case. The worker hasn't had a recorded injury or illness of the same type to the same body part, or had one but recovered completely before a workplace event or exposure brought the signs back (1904.6).
3. Meets a recording criterion. One or more of the general criteria in 1904.7, or a specific-case rule in 1904.8 to 1904.12.

The general recording criteria (1904.7)

A work-related case is recordable if it results in any of these:

• Death
• Days away from work
• Restricted work or transfer to another job
• Medical treatment beyond first aid
• Loss of consciousness, for any length of time
• A significant injury or illness diagnosed by a physician or other licensed health care professional: cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum

Not work-related, even at work (1904.5(b)(2))

These are the exceptions questions like to test. The case is not work-related if the injury or illness:

• Happened to the worker while present as a member of the general public
• Results solely from a non-work event or exposure outside the work environment, even if symptoms surface at work
• Results solely from voluntary participation in a wellness program or in a medical, fitness or recreational activity, such as a flu shot or an exercise class
• Results solely from eating, drinking or preparing food or drink for personal consumption (but food poisoning from food the employer supplied, or food contaminated by a workplace contaminant such as lead, is work-related)
• Results solely from personal tasks at the establishment outside assigned working hours
• Results solely from personal grooming, self-medication for a non-work condition, or is intentionally self-inflicted
• Is a motor vehicle accident on a company parking lot or access road while commuting
• Is the common cold or flu
• Is a mental illness, unless the employee voluntarily provides a professional's opinion that it is work-related

Step 2: first aid or medical treatment?

This is where most recordability questions turn. Medical treatment is "the management and care of a patient to combat disease or disorder." It does not include visits solely for observation or counseling, diagnostic procedures such as x-rays and blood tests, or first aid (1904.7(b)(5)(i)).

The first aid list in 1904.7(b)(5)(ii) is complete. OSHA says plainly that no other procedure counts. Who gives the treatment doesn't matter: a physician applying a bandage is still giving first aid.

If a physician or other licensed health care professional recommends medical treatment and the worker doesn't follow it, the case is still recordable (1904.7(b)(5)(v)).

Step 3: count the days correctly

Day-count questions are where careful reading pays. From 1904.7(b)(3) and (b)(4):

• Start the count the day after the injury or illness began. The day of injury is never counted.
• Count calendar days, including weekends, holidays and days off, if the worker couldn't have worked them because of the injury.
• Follow the recommendation, not the worker. If a physician recommends days away and the worker comes in anyway, record the recommended days away. If the physician clears the worker to return and the worker stays home, stop the count on the return date the physician gave.
• Cap at 180 days. Entering 180 is adequate for longer cases.
• Restricted work means the worker can't do one or more routine functions (work regularly done at least once a week) or can't work the full scheduled day. A restriction that applies only to the day of injury isn't recorded. Producing less while still doing all routine functions is not restricted work.
• One entry per case. A case that starts in December and runs into January is recorded once, on the log for the year it happened.

Worked example: days away

A worker is hurt on a Wednesday. A physician recommends 4 calendar days at home. The worker shows up Thursday and works anyway.

Record it as a days-away case with 4 days, counted from Thursday. The worker coming in doesn't change the count, because 1904.7(b)(3)(ii) says the recommended days away "must be recorded whether the injured or ill employee follows the physician or licensed health care professional's recommendation or not."

Step 4: practice the classification

Cover the right column and decide each case yourself. Each answer comes from the rule cited.

The deadlines and numbers in one table

Two reporting traps worth knowing. A motor vehicle accident on a public road is not reported to OSHA unless it happened in a construction work zone, and events on a commercial or public transportation system (a plane, train, subway or bus) are not reported. Both are still recorded if the employer keeps records (1904.39(b)(3) and (4)). An in-patient hospitalization only for observation or diagnostic testing doesn't have to be reported (1904.39(b)(10)).

Records control and worker privacy

ASP Domain 9 names retention and worker privacy. The rules that apply:

• Privacy concern cases go on the 300 Log as "privacy case," with no name. The list is complete: injuries to an intimate body part or the reproductive system, sexual assault, mental illness, HIV infection, hepatitis or tuberculosis, contaminated needlesticks and sharps cuts, and other illnesses where the employee asks for the name to be left off (1904.29(b)(7) and (8)). Keep a separate, confidential list of case numbers and names.
• Employees get the names. When an employee or representative asks for the 300 Log, you must leave names on it, except for privacy cases (1904.35(b)(2)(iv)).
• Who is covered. Record cases for everyone on your payroll, and for workers not on your payroll whom you supervise day to day, such as temporary staff (1904.31).
• Sharing outside those groups. If you voluntarily share the forms with anyone else, remove names and other identifying information, with three exceptions, including an auditor or consultant you hired to evaluate the safety program (1904.29(b)(10)).

To practice the privacy rules, use the OSHA recordkeeping summaries and employee involvement questions and the questions on access to employee exposure and medical records, which cover the separate 29 CFR 1910.1020 rule.

The incidence rate math

BLS gives the formula and the base:

Incidence rate = (number of injuries and illnesses × 200,000) ÷ employee hours worked

The 200,000 represents 100 employees working 40 hours a week for 50 weeks. For the count, BLS adds the OSHA 300A columns for cases with days away (H), job transfer or restriction (I) and other recordable cases (J). Fatalities aren't part of this nonfatal rate. DART uses only H + I. Hours worked exclude paid time off such as vacation, sick leave and holidays.

BLS's worked example

A company logs 7 cases and 400,000 hours worked. 3 of them involve days away, restriction or transfer.

• Total recordable rate: (7 × 200,000) ÷ 400,000 = 3.5
• DART rate: (3 × 200,000) ÷ 400,000 = 1.5

Try one more

A site has 5 recordable cases in the year: 2 with days away, 1 with restricted work and 2 others. Employees worked 236,000 hours.

• Total recordable rate: (5 × 200,000) ÷ 236,000 = 1,000,000 ÷ 236,000 = 4.24
• DART rate: (3 × 200,000) ÷ 236,000 = 600,000 ÷ 236,000 = 2.54

The common slip is putting all 5 cases into DART. The 2 "other recordable" cases (column J) belong only in the total rate. The incidence rate formula with its source and the DART rate formula show the column math, and the OSHA incident rate calculator checks your answers.

How to study it

1. Learn the three-test order (work-related, new case, criterion) and apply it to every scenario before you look at the answers.
2. Memorize the first aid list as one block. Anything not on it is medical treatment, and most questions hinge on one pair, such as Steri-Strips versus sutures.
3. Make one card with every number from the deadlines table above.
4. Do the rate math by hand until the 200,000 base and the H + I rule for DART are automatic. The ASP formula sheet with worked examples groups this with the rest of the Domain 1 math.
5. Practice with real rule text. The OSHA recordkeeping practice questions for the ASP quote the paragraph behind every answer, and the full 29 CFR 1904.7 text is free to read.

Domain 9 is 5% of the ASP and Domain 1 is 10%, so fit recordkeeping into the weekly plan in the ASP study guide and 12-week plan rather than giving it a week of its own. To see how you're doing across all nine domains first, take the free diagnostic.

FAQ

Is OSHA recordkeeping on the ASP exam?

BCSP's ASP11 outline doesn't name 29 CFR 1904, but it lists calculating lagging indicators such as incidence rates and lost time, interpreting lagging indicators, and understanding reporting and records control, including retention and worker privacy. Those tasks rest on the recordkeeping rule and BLS's incidence rate method.

What makes an injury recordable?

It must be work-related, be a new case, and meet a general criterion (death, days away, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosed injury or illness) or a specific-case rule such as needlesticks or hearing loss (29 CFR 1904.4 and 1904.7).

Is a prescription recordable?

Yes. Prescription medication is medical treatment, and so is a professional's recommendation to take an over-the-counter drug at prescription strength. Prescription medications used solely for diagnosis, such as eye drops to dilate pupils, are not.

How long do I have to record a case and to report one?

Enter a recordable case on the 300 Log within 7 calendar days. Report a fatality to OSHA within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours.

How long must OSHA injury records be kept?

5 years following the end of the calendar year the records cover, for the 300 Log, the privacy case list, the 300A summary and the 301 forms (29 CFR 1904.33).

What goes in the DART rate?

Cases with days away from work (column H) plus cases with job transfer or restriction (column I), times 200,000, divided by hours worked. Other recordable cases (column J) are left out.