2.3 Injury & Illness Recordkeeping (29 CFR 1904)

Injury & Illness Recordkeeping (29 CFR 1904)

Accurate recordkeeping is a critical component of occupational health and safety. Under 29 CFR Part 1904, OSHA requires employers to record and report work-related injuries and illnesses. These records do not determine fault or liability, nor do they prove that a safety standard was violated. Instead, they serve as a valuable tool for employers, employees, and OSHA to identify hazardous tasks, analyze injury trends, and implement target interventions to improve safety.

Scope and Exemptions

Not all employers are required to maintain standard injury and illness records. OSHA provides two main exemptions from the recordkeeping requirements:

1. Size Exemption: Employers with 10 or fewer employees at all times during the entire preceding calendar year are exempt from keeping OSHA injury and illness records (Forms 300, 300A, and 301). This count includes part-time, temporary, and seasonal workers.
2. Industry Exemption: Employers in certain low-hazard industries are partially exempt. These industries include retail trade, finance, insurance, real estate, and services (such as doctor offices or schools), which are classified under specific North American Industry Classification System (NAICS) codes designated by OSHA.

Critical Note: Even if an employer is exempt from routine recordkeeping due to size or industry, they must still comply with the requirements to report severe injuries (fatalities, hospitalizations, amputations, and eye losses) to OSHA, and they must participate in annual surveys if specifically requested in writing by the Bureau of Labor Statistics (BLS) or OSHA.

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The OSHA Recordkeeping Forms

Employers who are not exempt must maintain three primary forms. These records must be kept on-site at each establishment for a period of five years following the end of the calendar year they cover.

1. OSHA Form 300: Log of Work-Related Injuries and Illnesses

This form is a detailed running log of all recordable work-related injuries and illnesses that occur during the calendar year. For each case, the employer must record:

• The employee's name and job title.
• The date of the injury or onset of illness.
• The specific location where the event occurred.
• A brief description of the injury or illness (e.g., "Fractured left wrist due to fall from ladder").
• The classification of the case (death, days away from work, job transfer/restriction, or other recordable case).
• The number of days the employee was away from work or on restricted duty.

2. OSHA Form 301: Injury and Illness Incident Report

For every case recorded on the Form 300 Log, the employer must complete an individual OSHA Form 301 (or an equivalent form, such as a state workers' compensation first report of injury). The Form 301 provides deeper details about the incident, including:

• What the employee was doing just before the incident.
• How the injury occurred (e.g., "Contact with moving parts of conveyor belt").
• The specific tools, equipment, or substances involved.
• The nature of the injury and the part of the body affected.
• The name of the healthcare professional who treated the employee. The Form 301 must be filled out within 7 calendar days of the employer receiving notice that a recordable injury or illness has occurred.

3. OSHA Form 300A: Summary of Work-Related Injuries and Illnesses

At the end of each calendar year, employers must compile the data from the Form 300 Log into the Form 300A Summary. This form shows the total number of cases, total days away from work or restricted duty, and total injuries/illnesses by category, without displaying individual employee names.

• Executive Certification: A company executive (such as the owner, a corporate officer, or the highest-ranking manager at the site) must sign and certify the Form 300A under penalty of law, confirming that they have reviewed the records and believe them to be true and accurate.
• Posting Period: The Form 300A must be posted in a conspicuous location where employee notices are normally placed from February 1 to April 30 of the year following the recordable events. For example, the 2025 summary must be posted from February 1, 2026, through April 30, 2026. If no injuries occurred, the employer must still fill out the form with zeros, certify it, and post it.

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What Makes an Injury or Illness Recordable?

An injury or illness must be recorded on the OSHA Form 300 Log if it is work-related, represents a new case, and meets one or more of the following criteria:

• Death: Any work-related fatality.
• Days Away from Work: The injury forces the employee to miss at least one full day of work following the day of the incident.
• Job Transfer or Restriction: The employee is unable to perform all of their routine job functions, or is transferred to another job.
• Medical Treatment Beyond First Aid: Any treatment not defined as first aid.
• Loss of Consciousness: Even if only for a brief moment.
• Significant Injury/Illness: Diagnosed by a physician or other licensed health care professional (PLHCP), such as a fractured bone, punctured eardrum, or occupational disease (e.g., cancer, tuberculosis).

First Aid vs. Medical Treatment

Distinguishing between first aid and medical treatment is a common source of confusion. OSHA defines "First Aid" strictly through a list of 14 specific treatments in 1904.7(b)(5)(ii). Any treatment not on this list is considered medical treatment.

• First Aid (Not Recordable): Using non-prescription medication at non-prescription strength; administering tetanus immunizations; cleaning, flushing, or soaking wounds on the skin surface; using bandages, Band-Aids, butterfly bandages, or Steri-Strips; hot or cold therapy; non-rigid support (such as elastic wraps); temporary immobilization during transport; drilling a nail to relieve pressure; using eye patches; removing splinters with tweezers; finger guards; massage; or drinking fluids to relieve heat stress.
• Medical Treatment (Recordable): Using prescription medication (or non-prescription medication at prescription strength); using sutures, staples, or surgical glue to close wounds; rigid immobilization (casts, splints); physical therapy or chiropractic treatment.

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Severe Injury Reporting Thresholds

Under 29 CFR 1904.39, all employers must report severe incidents directly to OSHA within strict timeframes. These deadlines begin the moment the employer learns of the incident:

• Within 8 Hours: The death of any employee from a work-related incident must be reported.
• Within 24 Hours: Any work-related in-patient hospitalization of one or more employees (involving admission for care, not just observation), any amputation, or the loss of an eye. Reports must be made by phone to the local OSHA Area Office, the national hotline (1-800-321-OSHA), or via the online portal. If the incident occurs more than 30 days after the event (or 24 hours for hospitalization/amputation/eye loss), it does not need to be reported, but must still be recorded if applicable.