Jenkins Academy of Applied Technology · RK-001 · v1.0.0

OSHA Injury and Illness Recordkeeping & Reporting — learner reference

Course developed by Todd Jerome Jenkins, MS, CSP.

Fourteen lessons covering OSHA Part 1904 decisions, forms, severe-event reporting, annual submission, access and learning. Allow approximately 3–4 hours including the workplace exercises; pace varies.

The employer must determine actual jurisdiction and applicability, assign reporting and recordkeeping contacts, use actual OSHA forms and secure records, verify decisions and provide workplace-specific instruction. Online completion does not submit a report or certify a real log.

1. Understanding the reporting system

By the end: Separate internal reporting, OSHA recording, severe-event notice, annual submission, compensation and investigation.

A supervisor hears that a temporary worker was taken to hospital. Care and protection from continuing hazards come first. The supervisor receives the report, activates the employer response and immediately escalates a possible severe outcome. A finished investigation or incident form is not a prerequisite for getting help or assessing a notification deadline.

One event can start several processes. Internal reporting alerts the employer. OSHA recording evaluates the case and documents qualifying cases on the required records. Direct severe-event notification alerts the agency to specified outcomes. Annual electronic submission supplies specified establishment data. Workers’ compensation addresses a separate claim system. An investigation examines work conditions and opportunities for improvement.

These processes share facts but have different decisions, contacts and deadlines. Recording or reporting a case does not by itself establish fault, an OSHA violation or entitlement to compensation. The insurer’s decision does not replace the recordkeeper’s analysis. A low-severity event can still reveal a serious control problem.

In the hospital example, the supervisor should establish who knows the worker’s admission status, who makes the agency report and which employer provides day-to-day supervision. Telling the staffing agency is useful coordination; it is not proof that OSHA was notified. Track each duty and preserve its confirmation separately. Use fictional facts in classroom exercises and secure systems for actual health information.

Basis: 29 CFR 1904.0, 1904.29, 1904.35, 1904.39 and 1904.41

2. Recognizing urgent OSHA reporting obligations

By the end: Distinguish qualifying event windows, notification clocks, exceptions and the actual agency reporting route.

Direct reporting is separate from the OSHA log. Under the federal rule, a work-related fatality that occurs within 30 days of the incident must be reported within eight hours. A qualifying inpatient hospitalization, amputation or loss of an eye that occurs within 24 hours of the incident must be reported within 24 hours. Distinguish the incident-to-outcome qualifying window from the time allowed to notify OSHA after the outcome is known. Delayed knowledge rules apply when the employer or its agents learn later of the outcome or its work relationship.

Inpatient hospitalization means formal admission to inpatient service for care or treatment. Emergency-department treatment, an overnight stay, diagnostic testing or observation alone does not establish that trigger. An amputation can be reportable without hospitalization. Physical loss of an eye differs from loss of sight, although another reporting trigger may apply. Confirm facts without delaying an already triggered report.

For federal reporting use the area office by telephone or in person, the OSHA toll-free reporting number, or the agency’s online reporting application. If the area office is closed, use the hotline or online route; a voicemail, email or fax to the closed office is not a substitute. Record the establishment, location, time, outcome, affected employee information, contact and brief description, and preserve confirmation.

Specific exceptions include qualifying public-road motor-vehicle events outside a construction work zone and events on commercial or public transportation systems. These reporting exceptions do not decide log recordability. Work-related fatal heart attacks and qualifying inpatient care after heart attacks still require assessment under the rule. Identify the governing State Plan, which may require different outcomes or shorter reporting periods. Keep current primary and alternate contacts available before an event.

Basis: 29 CFR 1904.39; OSHA Report a Fatality or Severe Injury; governing State Plan rules

3. Determining which requirements apply

By the end: Document jurisdiction, company-size, industry, establishment and agency-request decisions separately.

Begin with jurisdiction and the employer’s actual establishments. Federal OSHA and approved State Plans have defined coverage, and public-sector coverage differs. The federal small-employer partial exemption considers the entire company: ten or fewer employees at all times during the previous calendar year generally qualifies, unless written agency direction requires records. Include relevant full-time, part-time, seasonal and supervised temporary workers when evaluating the count; do not use one small location to hide a larger company.

The industry partial exemption is a separate establishment decision under the current list in Subpart B Appendix A. Identify the actual industry classification and activities rather than relying on a general company label. A partial exemption from routine logs does not remove covered employers’ severe-event reporting duties or other applicable safety obligations.

Routine log applicability, annual electronic submission and responses to written OSHA or BLS requests are distinct. The size exemption uses company employment; ITA thresholds generally use establishment employment. The two different Appendix A lists in Part 1904 serve different purposes: Subpart B concerns routine-recording exemptions, while Subpart E concerns electronic submission. They are not interchangeable.

For practice, a company has 18 employees across three sites, each with fewer than ten. The sites cannot each claim the company-size exemption. Review industry and jurisdiction separately, document the evidence and assign a review owner. Recheck when operations, employment, locations, agency directions or rules change. A template or course cannot determine coverage without those facts.

Basis: 29 CFR 1904.1–1904.3, 1904.37, 1904.41 and 1904.42

4. Receiving reports and protecting employees

By the end: Receive reports without deterrence, explain usable reporting routes and protect against retaliation.

Employees need a reasonable procedure for promptly and accurately reporting work-related injuries and illnesses. Explain how and where to report, the right to report, access to records and protection against retaliation. A procedure is not reasonable if it deters or discourages a reasonable employee from reporting. It must accommodate an illness or injury whose nature or work connection becomes apparent later.

Receive the report respectfully. Ask what happened, when symptoms or the connection became known, what care is needed and whether others remain exposed. A supervisor can collect essential facts without demanding a diagnosis or deciding credibility on the spot. Provide an alternate route if the normal supervisor is unavailable or involved in the concern. Use language and access arrangements workers can actually understand and use.

Do not discharge or discriminate against someone for reporting a work-related injury or illness. Examine discipline, attendance rules, drug testing and incentives for their actual purpose and effect. Consistent legitimate safety rules and lawful testing are not categorically forbidden, but the act of reporting must not become the reason for punishment. An automatic penalty for every report can suppress useful information.

A worker reports wrist symptoms after recognizing a connection to repeated work. The supervisor should arrange care and prompt review, preserve when the employee understood the problem and avoid automatic late-report discipline. Evaluate hazards and recording separately. A later nonrecordable finding does not erase reporting rights. Teach the reporting process during workplace instruction and check understanding through a short explanation in the employee’s own words.

Basis: 29 CFR 1904.35–1904.36; OSH Act section 11(c)

5. Determining work-relatedness and new cases

By the end: Use the actual work-relatedness exceptions and distinguish a new case from an existing case update.

A case is work related when a work event or exposure causes or contributes to the condition or significantly aggravates a pre-existing condition. The work environment includes the establishment and other places where an employee works or is present as a condition of employment. Apply the rule’s presumption and its specific exceptions using facts; fault and preventability are different questions.

Exceptions require an actual match. Examples include presence as a member of the public, symptoms solely from nonwork events, certain voluntary wellness or recreational participation, specified personal food consumption or personal tasks, personal grooming, intentional self-harm, ordinary commuting accidents in the employer’s parking area, the common cold or flu, and the rule’s specific mental-illness provision. Do not turn an exception into a broad exclusion for every personal action or every infection.

Travel and home work have particular rules. Work-directed travel activities can be covered, while a personal detour or ordinary commute from an established home-away-from-home may be excluded. At home, consider whether the injury is directly related to performing work rather than the general home environment. Record what the person was doing rather than using location alone.

A new case involves no previously recorded same-type condition affecting the same body part, or complete recovery followed by a new work event or exposure causing recurrence. A flare-up without a new event may require updating the existing case. Obtain appropriate clinical clarification when needed. Keep a concise decision trail: facts, applicable provision, new-versus-existing determination, decision owner and what new information would require review.

Basis: 29 CFR 1904.5 and 1904.6

6. Deciding whether a case is recordable

By the end: Apply the complete recording decision and document both recordable and nonrecordable outcomes.

For an employer required to keep records, assess whether an injury or illness is work related, is a new case and meets a general or special recording criterion. Work-relatedness alone does not make every report recordable. Conversely, the absence of lost workdays does not establish a nonrecordable case.

General criteria include death, days away, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness and specified significant diagnoses by a physician or other licensed health care professional. A diagnosed fractured bone, punctured eardrum, cancer or chronic irreversible disease can require recording even when the worker remains at work and receives no treatment beyond first aid. Special criteria require a separate check.

The recordkeeper obtains enough information about treatment, recommended restrictions, days away, diagnosis and exposure to decide promptly. When several clinicians provide differing recommendations, apply the rule’s provisions concerning the most authoritative recommendation and the actual treatment or lost/restricted work; do not simply select the opinion that produces the lowest rate. Questions about ambiguous clinical facts need appropriate clarification.

Consider a worker with a work-related new fracture who finishes the shift and returns the next day. The diagnosis can make the case recordable. Consider another worker with a small cut, a simple dressing and no other criterion: it may be nonrecordable, but the internal report and hazard correction still matter. Document the reason and revisit when treatment, diagnosis or restrictions change. Never pressure a clinician or worker to alter care so the log looks better.

Basis: 29 CFR 1904.4 and 1904.7–1904.11

7. First aid versus medical treatment

By the end: Distinguish the exact first-aid list, diagnostic procedures and treatment beyond first aid.

For recording purposes, first aid is the rule’s complete treatment list, not a general label for minor care. The status of the person giving care does not decide it. A physician can provide only first aid, and a nonphysician can provide treatment beyond first aid. Observation, counseling and diagnostic procedures alone are not medical treatment under this criterion, although a resulting diagnosis or another criterion can still make the case recordable.

The first-aid list includes nonprescription medication at nonprescription strength, tetanus immunizations, cleaning or flushing surface wounds, wound coverings and butterfly bandages or Steri-Strips, hot or cold therapy, nonrigid supports, temporary immobilization during transport, pressure relief for a nail or blister, eye patches, specified simple removal of foreign material, finger guards, massage and fluids for heat stress. Read the exact conditions in 1904.7(b)(5)(ii) before applying a borderline category.

Examples beyond first aid include sutures or wound-closing glue, prescription medication and medication at prescription strength, rigid immobilizing devices and physical therapy or chiropractic treatment. A precautionary prescription may still meet the treatment criterion; whether the worker chooses to fill it does not automatically remove the recommendation. A simple diagnostic X-ray is different from treatment, but a fracture shown by that X-ray is a separate criterion.

Use actual clinical documentation. If the record only says “pain medicine” or “brace,” clarify the drug, strength, recommendation and device rather than guessing. Keep medical decisions with qualified clinicians. The employer’s job is accurate recording and appropriate care, not steering treatment toward first aid to preserve a low incident rate.

Basis: 29 CFR 1904.7(b)(5); OSHA first-aid and treatment guidance

8. Classifying cases and counting days

By the end: Classify the most serious outcome and count the correct calendar days without counting the event day.

Classify a case by its most serious outcome: death, days away, restricted work or transfer, or another recordable case. Use one outcome category for the case and keep the relevant day counts. If the outcome changes, revise the log so the annual summary reflects the current classification rather than creating a duplicate incident.

Do not count the injury or illness day. Start subsequent calendar days when the worker cannot work because of the case or is unable to perform routine functions or the full scheduled shift. Include weekends, holidays and other nonscheduled days when the condition would have prevented the relevant work. Do not use scheduled shifts alone. Routine functions are activities performed at least once per week; evaluate actual restrictions and recommendations.

Days away and restricted/transfer days have a combined 180-calendar-day recording cap. Do not put a 180-day allowance in each column. When a case continues at year-end, estimate the expected days for the summary and update the log when the actual count is known or the cap is reached. An unrelated departure can stop counting; a departure because of the injury requires the rule’s estimate, not automatic zero days.

Work through a Friday injury followed by a recommendation to stay away through Monday and return Tuesday. Saturday, Sunday and Monday count: three days away. If a worker then returns with a restriction affecting routine lifting, evaluate and count restricted days separately. Use the clinician’s recommendation and the rule’s actual-work provisions; do not call a restriction “light duty” and omit it because the person remained on payroll.

Basis: 29 CFR 1904.7(b)(3)–(4); OSHA Forms 300 and 300A instructions

9. Recognizing special recording criteria

By the end: Recognize special-case triggers and refer clinical or standard-specific decisions to the appropriate reviewer.

Some cases require special analysis even when the general checklist seems inconclusive. Work-related punctures and cuts from sharps contaminated with another person’s blood or other potentially infectious material are recorded as injuries and privacy cases. An unbroken-skin splash is not automatically a sharps case; evaluate actual diagnosis and other recording criteria, together with separate bloodborne-pathogens response duties.

Medical removal under an OSHA standard has its own recording rule and classification. Identify whether removal was required by the standard, rather than assuming that every precautionary temporary reassignment is a mandated medical removal. The substance-specific protection and medical requirements remain separate from the log entry.

Occupational hearing-loss recording requires a work-related Standard Threshold Shift and a total hearing level of at least 25 dB above audiometric zero averaged at 2000, 3000 and 4000 Hz in the same ear. The STS comparison and total-hearing threshold are different tests. The rule permits a retest within 30 days and specifies resulting recording or correction duties. Use the qualified professional’s findings; a generic course does not interpret an audiogram or replace hearing-conservation requirements.

For tuberculosis, evaluate occupational exposure to a known active case followed by infection evidenced as specified in the rule; a pre-employment positive test alone is not automatically a workplace case. Privacy cases also include specified intimate/reproductive injuries, sexual assault, mental illness, HIV/hepatitis/TB and certain voluntarily requested illness privacy. Use “privacy case” on the log and keep the separate name-to-case list securely. Do not treat every injury as eligible for optional name removal.

Basis: 29 CFR 1904.8–1904.11 and 1904.29(b)(6)–(9)

10. Completing Forms 300 and 301

By the end: Complete accurate, timely 300 and 301 entries and apply the correct privacy controls.

The 300 Log summarizes recordable cases; the 301 Incident Report provides case detail. For a new recordable case, complete both within seven calendar days after receiving information that it occurred. This clock is not the same as the eight- or 24-hour severe-event notification clock. Do not wait for a completed root-cause investigation, insurance acceptance or year-end review.

Assign a case number and enter the correct employee, job, date, location, event and injury or illness information. Describe what happened clearly enough to be useful without blame labels. Enter the most serious outcome, relevant day totals and correct injury/illness category. Preserve accurate details rather than converting every event to “employee failed to pay attention.”

An equivalent form must contain the same information, be as readable and understandable and follow the rule’s instructions. A workers’ compensation form is not automatically equivalent; compare the fields. Electronic records are acceptable when equivalent requirements, access and production times are met. The employer must still be able to provide usable copies.

Apply required privacy-case name substitution and keep the separate confidential identity list. For descriptions that could identify a privacy-case employee, use permitted discretion while retaining useful severity and general cause information. Requests from people outside the specified government/employee access routes require separate disclosure review and removal of identifiers as applicable. Do not post the full 300 Log as the annual summary. In a fictional practice case, complete a mock entry, compare it to the case facts and identify the owner of later corrections. Never place real medical details in a public learner worksheet.

Basis: 29 CFR 1904.29; OSHA Forms 300, 300A and 301

11. Managing multiple sites and employers

By the end: Assign the correct establishment and recording employer using actual work and supervision.

A recordkeeping establishment is not always the same as a project, payroll group or legal company. Generally keep a separate log for each establishment expected to operate at least one year. The rule permits specified combined arrangements for short-term establishments. Identify the actual locations, expected duration and workers covered before selecting a structure.

Central recordkeeping can work when case information reaches the central location within seven calendar days after receiving information that a recordable case occurred and the required copies can be produced within applicable access deadlines. Assign a contact who can retrieve records when the usual recordkeeper is absent. Centralization does not extend employee or government access periods.

Record injuries and illnesses of employees on payroll and other workers whom the employer supervises day to day, subject to the rule. In temporary labor, payment of wages or provision of a safety orientation does not alone decide recording responsibility. Determine who actually directs the details, means, methods and processes of the work, and coordinate so a case is recorded only once.

For a worker temporarily at another establishment of the same employer, use the location rules in 1904.30 rather than creating a duplicate log entry at both places. Contractor employers usually keep their own workers’ cases when they retain day-to-day supervision; examine the actual arrangement. Set up host/staffing or multiemployer contacts in advance. If responsibility is disputed after an event, escalate promptly and document facts rather than allowing both employers to assume the other acted. Severe-event reporting needs its own responsible-person review.

Basis: 29 CFR 1904.30–1904.31

12. Completing the annual cycle

By the end: Review, reconcile, certify and post the correct annual summary, including zero-case years.

At year-end, review the 300 Log for completeness and accuracy, correct identified deficiencies, total the columns and prepare a 300A summary. A covered establishment still prepares and posts its summary for a year with zero recordable cases. Reconcile the summary to the log and use the correct establishment employment and hours-worked data.

Calculate annual average employment using the form instructions and actual pay-period information. Hours worked include the relevant full-time, part-time, temporary and seasonal work covered by the log; do not simply substitute paid hours that include vacation or sick leave. Keep support for estimates when exact hours are unavailable. Denominators affect interpretation as well as submitted data.

A qualifying company executive must examine the log and certify a reasonable belief that the summary is correct and complete based on knowledge of the recording process. The rule identifies the executive categories: an owner for a sole proprietorship or partnership, a corporate officer, the highest-ranking company official working at the establishment, or that official’s immediate supervisor. A recordkeeper’s preparation alone is not the executive certification.

Post the certified 300A no later than February 1 and keep it posted through April 30 in the required conspicuous location where employee notices are customarily posted. Ensure it is not altered, defaced or covered. An electronic posting alone does not replace the federal physical-posting requirement. Do not post the 300 Log or 301 reports, which contain individual case information. Retain the summary and address the separate ITA decision and deadline even after posting is complete.

Basis: 29 CFR 1904.32; OSHA 300A instructions

13. Submitting, retaining, and providing records

By the end: Apply the correct ITA, retention and requester-specific access rules rather than a universal deadline.

Electronic submission is an establishment-specific decision. Under the federal rule, establishments with 20–249 employees in Subpart E Appendix A industries submit 300A data. Establishments with 250 or more employees that must keep records also submit 300A data. Establishments with 100 or more employees in Appendix B industries submit specified 300 and 301 data as well. Check overlapping duties, actual peak employment, current industry lists and partial exemptions. Required annual submissions are due March 2 following the record year unless an applicable direction provides otherwise; retain the receipt and correct errors through the agency process.

Submit only the permitted fields and required establishment/EIN information through ITA. Do not include excluded names, addresses or other direct identifiers in narratives. Redaction of uploaded data does not authorize deleting required names from the employer’s original nonprivacy-case log. Retain the 300, privacy list, 300A and 301 for five years following the end of the calendar year they cover. Update stored 300 Logs with newly discovered recordable cases and changed classifications or outcomes; federal 1904.33 does not require updating stored 300A or 301 forms, though the employer may do so.

Employees, former employees and qualifying representatives can request relevant logs by the end of the next business day. An employee or personal representative can obtain that employee’s 301 by the same deadline. An authorized collective-bargaining representative’s 301 access is the specified case-information section, with personal identifiers removed, within seven calendar days. Preserve the rule’s required privacy substitutions and free first-copy arrangements; do not apply blanket name removal to every lawful log request.

Authorized government requests for Part 1904 records generally require copies within four business hours. Medical/exposure records under other standards have different access and retention rules. Route requests by record type and requester; do not promise a universal next-business-day deadline for all records. Maintain secure retrieval, request logs and evidence of delivery without delaying valid access.

Basis: 29 CFR 1904.33–1904.35, 1904.40–1904.42

14. Using records for learning

By the end: Use accurate records with worker input and control evidence, and recognize what a course score cannot establish.

A good recordkeeping system makes accurate decisions and helps people understand conditions of work. Examine tasks, exposure patterns, failed or difficult-to-use controls and changes in treatment or restrictions. The log is a defined dataset, not a complete inventory of hazards, close calls or worker experience. Nonrecordable events and successful adaptations can reveal important improvement opportunities.

Rates can support comparison only when the numerator, hours, workforce, period and case definitions match. A total recordable incidence rate uses recordable cases multiplied by 200,000 and divided by hours worked; a DART rate uses cases with days away, restriction or transfer rather than the number of days. Small denominators can produce large swings. Do not infer strong controls from one zero-case period or hide uncertainty behind a ranking.

For a fictional example, three recordable cases over 300,000 hours produce a rate of 2.0. That number does not explain whether lifting design, scheduling, maintenance, exposure or reporting barriers shaped the cases. Compare trends with inspections, worker input, exposure/control verification and evidence of whether corrective actions actually help. Report counts and context alongside rates.

Finish by applying the two written programs. Locate primary and alternate reporting contacts, severe-event responsibility, the decision worksheet, secure records and the anti-retaliation route. Review a fictional event from first report through classification, forms, summary, submission and learning. Resolve unclear duties with the employer before relying on the arrangement. The Academy final measures knowledge; it does not certify a real log, complete a statutory report or establish employer compliance.

Basis: 29 CFR 1904.0; OSHA Recommended Practices for Safety and Health Programs

Companion written program — published separately by Todd Jerome Jenkins

Official sources

Source review: October 23, 2026. Federal baseline; verify actual State Plan, statute, employer and work conditions. Guidance and Academy assessment rules are distinguished from statutory duties.