Todd Jerome Jenkins, MS, CSP, SMS, ASP, CHST, STSC

Safety Aficionado & Ph.D. Student

What Reporting & Recordkeeping Does OSHA Require?

Keeping workers safe in the workplace is your number one priority and your legal obligation under OSHA regulations. Even your best efforts sometimes aren’t enough, and an employee may become ill or injured. The worker must get the care they need. Per 29 CFR 1904, employers are subject to reporting and recordkeeping requirements for specific work-related injuries or illnesses. Failure to comply with this requirement can result in costly fines and penalties.

What Must Employers Report Injury and Illness Incidents?

Most companies and organizations that employ at least ten (10) people are required to track and report injuries and workplace illnesses. However, some businesses in so-called low-risk industries may be partially exempt from this requirement. If your company operates within one of the sectors listed in 29 CFR 1904 Appendix A to Subpart B, you may not have to report unless compelled by OSHA.

When Does OSHA Consider an Injury or Illness to Be Work-Related?

Per OSHA, an injury or illness is considered work-related if an event or exposure in the work environment caused, contributed to, or significantly aggravated a pre-existing condition. As you would suspect, OSHA describes the work environment as the buildings and other locations where one or more employees work or must be present as a condition of their employment.

What Illnesses and Injuries Must Be Reported?

For the most part, any injury or illness at your workplace will meet the general criteria and, therefore, must be recorded. Specific reporting requirements kick in when any of the following occurs:

  • – A work-related fatality.
  • – Work-related injuries or illnesses that result in loss of consciousness.
  • – Injuries and illnesses result in days away from work, restricted work, or transfer to another job.
  • – Any work-related injury or illness requiring medical treatment beyond first aid.
  • – Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
  • – Specific recording criteria are also in place for work-related needlesticks and sharps injuries, medical removal; hearing loss; and tuberculosis.

Remember that you also need to report any significant injury or illness diagnosed by a physician to OSHA. These reporting requirements may be the case even if there is no death, missed days of work, work restrictions, job transfer, medical treatment beyond first aid, or loss of consciousness.

What Does OSHA Consider First Aid?

Since OSHA states that medical treatment beyond first aid triggers the need for reporting, one must fully understand what that means. Per 1904.7(b)(5)(i)(C), OSHA defines first aid treatment as:

  • – Using a nonprescription medication at nonprescription strength;
  • – Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment);
  • – Cleaning, flushing, or soaking wounds on the surface of the skin
  • – Using wound coverings such as bandages, Band-Aids™, gauze pads; or using butterfly bandages;
  • – Administering hot or cold therapy;
  • – Applying a non-rigid means of support, such as elastic bandages, wraps, and non-rigid back belts;
  • – Using temporary immobilization devices such as splints, neck collars, and slings,
  • – Relieving pressure by putting a hole in a toenail or fingernail or draining fluid from a blister;
  • – Applying eye patches;

Suppose a worker requires treatment for an injury or illness beyond the scope of first aid listed here. In that case, the injury and subsequent treatment must be appropriately recorded and reported.

A Reportable Injury or Illness Occurs, Now What?

The first thing that needs to be done when a severe workplace injury or illness occurs is to take care of the employee. Summon emergency personnel, so the employee receives prompt medical attention. Once the patient is stabilized, and everyone is safe, you must complete the appropriate OSHA forms for reporting work-related injuries and illnesses, including forms 300, 300A, and 301.

Need the Forms?

Form 301: Injury and Illness Incident Report

Despite the number on the form, this is one of the first forms you’ll complete to report a workplace injury or illness. This form must be filled out within seven calendar days of when you’ve been notified that a recordable work-related injury or illness has occurred. Be aware that state workers’ compensation, insurance, or other forms may also be acceptable if they contain all the information requested on form 301. According to 29 CFR 1904, you must keep this form on file for five years.

Form 300: Log of Work-Related Injuries and Illnesses

According to OSHA, the 300 forms should be used to record every reportable workplace injury or illness. It includes information such as the names of injured employees, their position, date of injury, and a description of the injury or illness. You will also be asked to classify the nature of the incident (i.e., death, work restriction, time off). Every incident must first be recorded using Form 301, as noted above.

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

All establishments covered by Part 1904 must also complete the Summary Form 300A. Completing this form is a requirement even if there are no work-related injuries or illnesses to report for the year. If you have incidents to report, carefully enter them onto Form 301 using the information detailed on your Log. It is vital that your reporting is accurate to avoid OSHA penalties and fines.

OSHA Online Reporting Requirements

If your organization is required to report injuries and illnesses per 29 CFR 1904, you may be required to file online reports. OSHA’s initiative, Improve Tracking of Workplace Injuries and Illnesses, submitted on March 30, 2022, would require:

  • Organizations in specific high-hazard industries with 20 or more employees must electronically submit Form 300A Annual Summary information annually to OSHA.
  • Establishments with 100 or more employees in these industries must submit Form 300 and Form 301 annually to OSHA. They will also be required to submit their Form 300A Annual Summary information electronically.


Your legal obligation is to ensure your employees have a safe workplace free of known hazards. When your best efforts fail, and a worker dies, is injured, or becomes ill, you must use the appropriate forms to report the incident to OSHA. This requirement is in place to assist employers and OSHA in maintaining safe workplaces for all employees.


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