OSHA Injury Reporting and Recordkeeping: What Employers Must Document

OSHA imposes two separate duties after a workplace injury, and they are often confused. Reporting means telephoning or notifying OSHA directly about a severe event, on a clock measured in hours. Recordkeeping means maintaining an internal log of work-related injuries and illnesses that is posted once a year and produced on request. A small employer may be exempt from routine recordkeeping and still be required to report a fatality within 8 hours. Both duties come from federal regulation at 29 CFR Part 1904.

The reporting clock runs in hours

Severe events must be reported directly to OSHA. The deadlines are short and they run from when the employer learns of the event, not from the accident itself.

1. Within 8 hours

   A work-related fatality. The death must have occurred within 30 days of the work-related incident to trigger the duty.

2. Within 24 hours

   An inpatient hospitalization of one or more employees, an amputation, or the loss of an eye. These count when they occur within 24 hours of the work-related incident.

3. By the next business day

   An employee or their representative who asks for a copy of the 300 log is entitled to receive it, under the access rules in Part 1904.

4. Within 7 calendar days

   A recordable injury or illness must be entered on the internal log after the employer receives information that it occurred.

Reports are made by telephone to the nearest OSHA area office, through the agency's toll-free line, or with the online form. The current channels and the exact information to have ready are set out on OSHA's severe injury reporting page. Reporting is required of every employer covered by the OSH Act, including employers that are otherwise exempt from keeping records.

Watch out: "Inpatient hospitalization" means formal admission for care or treatment. An emergency-room visit for observation or diagnostic testing, without admission, generally does not trigger the 24-hour duty — but the distinction is factual and worth confirming rather than assuming.

Which employers keep records at all

Routine recordkeeping does not apply to everyone. Two partial exemptions sit in the regulation.

The first is size. An employer with ten or fewer employees at all times during the previous calendar year is partially exempt. The count is across the whole company, not per location.

The second is industry. Establishments in listed low-hazard industries — much of retail, finance, insurance, real estate and many service sectors — are partially exempt regardless of size. The list is an appendix to the regulation and is keyed to industry classification codes, so the answer depends on the code assigned to the establishment.

Partially exempt does not mean invisible. Those employers must still report severe events on the hours-based clock above, must still respond if OSHA or the Bureau of Labor Statistics surveys them in writing, and remain subject to the general duty to provide a workplace free of recognized hazards.

What makes an injury recordable

A case goes on the log when it is work-related, is a new case, and meets at least one recording criterion. Work-relatedness carries a presumption: an event occurring in the work environment is presumed work-related unless one of the narrow exceptions in the regulation applies, such as an injury while the employee was present as a member of the general public, or a common cold.

• Death.
• Days away from work.
• Restricted work activity or transfer to another job.
• Medical treatment beyond first aid.
• Loss of consciousness.
• A significant injury or illness diagnosed by a physician or other licensed health care professional.

The line between first aid and medical treatment is defined by a closed list in the regulation rather than by clinical judgment. Cleaning a wound, using a non-prescription medication at non-prescription strength, applying a bandage, and using hot or cold therapy are treated as first aid; prescription medication, sutures and rigid immobilization are not. The full list appears in the text of 29 CFR Part 1904. Certain cases are recordable regardless of treatment — needlestick and sharps injuries with contaminated material, medical removal under a health standard, tuberculosis infection, and hearing loss meeting a defined shift.

Note: The regulation states expressly that recording a case is not an admission of fault, negligence or compensability. A case can be recordable under Part 1904 and still be denied under a state workers' compensation system, and the reverse also happens.

Three forms and one posting season

The 300A summary is posted seasonally rather than continuously: it goes up in early February and stays up through the end of April in the year after the year it covers, in a place where employee notices are customarily displayed. Records are retained for five years following the end of the covered calendar year, and the 300 log must be updated during that period if a case's outcome changes.

Some establishments must also submit data to OSHA electronically each year, with the scope depending on employee count and industry. Because the covered categories have been revised more than once, confirm the current submission requirement on the agency's recordkeeping page rather than working from an old compliance memo.

The federal floor and the state layer

Part 1904 is the federal baseline. Roughly half the states operate their own OSHA-approved occupational safety plans, which must be at least as effective as the federal program and may be stricter. Some state plans cover only public-sector employees; others cover private employers too. A few require notification of additional event types or on shorter timelines.

Employers with sites in several states cannot assume one process fits all of them. The practical approach is to run the federal minimum everywhere and add the state-specific triggers where a site sits under a state plan. Contact information for each state plan is published by OSHA.

Recordkeeping also interacts with retaliation law. Part 1904 requires employers to have a reasonable procedure for employees to report injuries and forbids discouraging reports. Where several employees raise a safety concern together, a second and independent federal protection can attach, as described in our analysis of protected concerted activity without a union.

Common questions

The employee went to the ER but was sent home. Do I report it?

Only if they were formally admitted as an inpatient. Treatment and release, or admission solely for observation or diagnostic tests, generally falls outside the 24-hour reporting duty. The case may still be recordable on the 300 log if it meets a recording criterion such as medical treatment beyond first aid or days away from work. Reporting and recording are answered separately, and one does not imply the other.

Does a case involving a temporary or staffing agency worker go on my log?

Generally it goes on the log of whichever employer supervises the worker on a day-to-day basis, which is usually the host employer rather than the staffing agency. Both should communicate so the case is recorded once, not twice or not at all. Contract language does not override the supervision test. The host employer's reporting duty for a severe event is independent of who carries the case on a log.

Can employees see the log?

Yes. Current and former employees, their personal representatives and their authorized employee representatives have access rights under Part 1904, with the 300 log and the annual summary generally provided by the end of the next business day. An employee is entitled to their own 301 incident report. Employers must protect privacy-case names, which are kept on a separate confidential list rather than on the posted log.

What happens if we discover a case we missed last year?

Add it. The regulation requires records to be kept for five years and the 300 log to be updated during that retention period when new information emerges or an outcome changes. Late entry is far better than an inaccurate log, since accuracy is what an inspector evaluates. If the missed case was a reportable fatality or severe injury, notify OSHA immediately even though the hours-based deadline has passed.

A working sequence

1. Confirm the exemption status of each establishment. Check headcount for the prior calendar year and the industry code against the appendix list, site by site.
2. Write down the reporting decision tree. Fatality, inpatient admission, amputation, eye loss — with the responsible person and the after-hours channel named.
3. Train the first-aid line. Whoever triages injuries should know the closed first-aid list, because that single distinction drives most recording decisions.
4. Log within seven days. Build the deadline into the incident workflow rather than the year-end close.
5. Certify and post the summary on schedule. Executive certification is a named requirement, not a formality, and the posting window is fixed.
6. Reconcile with the injury claim file. The log and the claim file should describe the same event, though the legal tests differ, as our guide to workers' compensation claims and disputes explains.

Employers building this into written policy should keep the reporting instructions in the safety program rather than burying them in general staff rules, for the reasons set out in our guide to what a handbook creates and what it should avoid. Companies that also manufacture consumer products face a separate and unrelated notification regime, described in our guide to product recall reporting duties and records, and the two should not be run off the same checklist.