Evidence that damage decreases bone quality, increases fracture susceptibility, and serves as a remodeling stimulus motivates further study of what loading magnitudes induce damage in trabecular bone. In particular, whether damage occurs at the smaller strains characteristic of habitual, as opposed to traumatic, loading is not known. The overall goal of this study was to characterize damage accumulation in trabecular bone at small strains (0.20 – 0.45% strain). A continuum damage mechanics approach was taken whereby damage was quantified by changes in modulus and residual strain. Human vertebral specimens (n = 7) were tested in compression using a multi-cycle load – unload protocol in which the maximum applied strain for each cycle, ε_max, was increased incrementally from ε_max= 0.20% on the first loading cycle to ε_max= 0.45% on the last cycle. Modulus and residual strain were measured for each cycle. Both changes in modulus and residual strains commenced at small strains, beginning as early as 0.24 and 0.20% strain, respectively. Strong correlations between changes in modulus and residual strains were observed (r= 0.51 – 0.98). Fully nonlinear, high-resolution finite element analyses indicated that even at small apparent strains, tissue-level strains were sufficiently high to cause local yielding. These results demonstrate that damage in trabecular bone occurs at apparent strains less than half the apparent compressive yield strain reported previously for human vertebral trabecular bone. Further, these findings imply that, as a consequence of the highly porous trabecular structure, tissue yielding can initiate at very low apparent strains and that this local failure has detectable and negative consequences on the apparent mechanical properties of trabecular bone.