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Recordable versus reportable incidents: What’s the difference? Find out in this quick guide about how to comply with OSHA’s recordkeeping regulation, 29 CFR 1904.


If you have more than 10 employees or work in an industry with a higher-than-average potential for hazardous incidents—which covers nearly all metalworking shops and manufacturing facilities—then you’re subject to OSHA recording and reporting rules.

OSHA’s recordable versus reportable incidents: What’s the difference? What must a manufacturing plant share with the Occupational Safety and Health Administration?

Shop floor chiefs and safety managers need to know the answer to both these questions and be aware of the recordkeeping and reporting requirements necessary to stay in compliance of government regulations.

Every business should start with this baseline: If a worker suffers an injury, illness or dies while on the job, the company will likely need to record it. That’s the most basic definition of a recordable incident.

What Is an OSHA Reportable OSHA Incident?

OSHA is quite specific on what defines a reportable incident and what must be reported to the government within strict time restraints.

Workplace incidents such as in-patient hospitalization, amputations, heart attacks that happen to workers on the job, or work-related fatalities are all considered “serious” injuries and are reportable to OSHA. They must be reported directly to the agency—by phone or online—usually within hours.

A business must report any fatality within eight hours of learning of the death. It must notify OSHA of a serious reportable incident within 24 hours of becoming aware of it.

In-patient hospitalization encompasses all formal admissions to the in-patient service of a hospital or clinic for care or treatment, notes KPA in a blog post. “Hospitalization doesn’t necessarily mean that the employee stays overnight; if they’ve been admitted for in-patient treatment, the event must be reported.”

The reporting windows took effect when OSHA updated its recordkeeping standard, 29 CFR 1904, in 2015.

The chief reason for the change was to help identify workplaces with potentially chronic safety issues, former OSHA administrator David Michaels said in the fall of 2014.

“Hospitalizations and amputations are sentinel events, indicating that serious hazards are likely to be present at a workplace and that an intervention is warranted to protect the other workers at the establishment,” Michaels said. “Too often, after a fatality, when we inspect, we learn that other workers have already been injured at that establishment.”

For more information, see OSHA’s direct guidance on the recordkeeping standard.

Read more: Head, Face and Eye Protection for Your Workers: What to Use and When

“Not keeping your TRIR low can cost you money, your reputation and a high-quality workforce and mean lost time dealing with annoying paperwork.”

Handling COVID-19 Cases

The past year has seen employers do all they can to decrease the spread of COVID-19 inside their facilities and reduce its potential impact on their employees. Many have also grappled with the question of whether the illness is work-related and therefore recordable (or reportable) under OSHA’s recordkeeping standards. 

In late 2020, OSHA added new questions and answers on its frequently asked questions site that further clarify when employers must inform the agency if employees are hospitalized or die due to COVID-19.

The guidance explains that exposure to COVID-19 in the workplace is a work-related incident. OSHA says an employer must report the fatality within eight hours of determining both that the worker has passed away due to COVID-19 and that the death occurred within 30 days of exposure to COVID-19 in the workplace.

In June 2021, OSHA issued emergency COVID-19 workplace safety rules for employers, but they only applied to the health care industry and not to other high-risk workplaces. The Biden administration had initially requested an emergency temporary standard that covers all workplaces.

How to Maintain OSHA-Compliant Recordable Incident Logs

Reports and logs are key elements of the OSHA recordkeeping rules. A business must maintain incident reports and logs on-site of all recordable incidents for at least five years. You’re not required to submit these reports to OSHA, but you must be able to provide them if asked or during inspections.

Inspectors will typically review logs when they visit a facility. OSHA requires businesses to fill out and keep on-site three types of forms for documenting recordable incidents.

  1. Form 301: Injury and Illness Incident Report
    This is the form that a business must fill out for each recordable incident. You must document an incident within seven days of learning of it. This form includes the most detail about who was harmed and how.
  2. Form 300: Log of Work-Related Injuries and Illnesses
    This form is a running log for recording all of a business’s recordable incidents for a calendar year. It encapsulates the pertinent details from each 301 incident. It can help the safety team identify and address areas of concern so it can improve safety across the facility.
  3. Form 300A: Summary of Work-Related Injuries and Illnesses
    This form is a “dashboard” report of a facility’s recordable incidents for a year by number of cases, days of lost work and incident type. OSHA requires that a site display it from February through April annually. This data is used to calculate the recordable incident rate.

OSHA requires that businesses give all workers the right to ask for and to review forms 300 and 300A in their entirety and be given access to much of Form 301, too, as specified in 29 CFR Part 1904.35.

Failure to maintain these records can lead to a $7,000 fine by OSHA.

What Are OSHA Recordable Incidents?

OSHA has explicitly outlined the type of incidents safety managers need to manage and document. Here’s an official list of OSHA recordable incidents:

  • Any work-related diagnosed case of cancer or chronic irreversible diseases.
  • Any work-related injury resulting in punctured eardrums or fractured/cracked bones or teeth.
  • Any work-related injury or illness requiring medical treatment beyond first aid.
  • Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work or transfer to another job.
  • Any work-related fatality.

There are also special recording criteria for work-related cases involving needlesticks, sharps injuries, medical removal, hearing loss and tuberculosis.

It’s crucial to note that not every incident is recordable. Generally speaking, the case should be an event or exposure in the work environment that either caused or contributed to the resulting condition during work hours. If not, the case is not recordable.

If you’re ever in question about whether you must log an incident, OSHA recommends that you contact the agency and ask. That’s the easiest way to avoid a compliance issue.

Read more: Machine Safety: Here’s Why You Should Be Taking It Seriously

What Is the Total Recordable Incident Rate and Why Does it Matter?

Beyond the incident reports required after an injury, illness or fatality—and the ongoing annual log of all recordable incidents—OSHA inspectors (and many others) use the recordable incident data to determine total recordable incident rate for a facility.

TRIR is a percentage rate of recordable incidents per 100 employees. To calculate your TRIR, you multiply the number of recordable incidents by 200,000, then divide by the total number of hours worked in a year by your employees.

OSHA uses the 200,000 number because it represents the hours 100 employees would work in a year, or 100 employees times 40 hours a week times 50 weeks a year.

To help figure out your TRIR, use our helpful, interactive calculator for TCR and DART.

The lower the number, the better your safety record. And TRIR is important because it’s used in many different ways that can affect a business’s bottom line, points out a Slice Products blog post.

OSHA uses TRIR to monitor your business’s progress on improving its safety record; investors weigh it when evaluating your business for funding; insurers look at it when setting rates; buyers inquire about it when selecting suppliers; and would-be workers check it out when applying for jobs and evaluating safety culture.

Given how much rides on this one number, it’s worth paying close attention to it. Not keeping your TRIR low can cost you money, your reputation and a high-quality workforce and mean lost time dealing with annoying paperwork.
 

Read more: Confined Space Safety: What’s the Correct PPE, Equipment for Working in Hazardous Locations?


What insights do you have to share about handling recordable and reportable OSHA incidents? Share your thoughts in the comments below.
 

Recordable versus reportable incidents: What’s the difference? Find out in this video:

Recordable vs. Reportable Incidents Poll

Are you well versed in OSHA’s recording and reporting rules?

To ensure OSHA compliance, it’s important senior managers and your safety team know the difference between recordable and reportable incidents.

Take our poll to see if you need to add a little more awareness training.

Do you know the four on-the-job incidents that require you make a report directly to OSHA by phone or online?

Talk to Us!

If you have one employee hit another employee in the mouth and required stitches, will this be considered a recordable accident that would need to be listed on the 300 log? Employee was not admitted in the hospital or lost time from work.

14  

That would be a recordable incident. Recordable incident include any work-related injury or illness requiring medical treatment beyond first aid.

1  

If you have an employee that got a puncutured wound when he was drilling and punctured his left hand. No hospital visit applied and was taken care of with First Aid. Will this be something that we will need to log in the Ohsa form? Employee contiunue working with no problem afterwards.

   

If an employee is a member of the general public and not an employee and dies at the workplace ( staying as a guest at the hotel) is it reportable?

   

1904.31(a)

Basic requirement. You must record on the OSHA 300 Log the recordable injuries and illnesses of all employees on your payroll, whether they are labor, executive, hourly, salary, part-time, seasonal, or migrant workers. You also must record the recordable injuries and illnesses that occur to employees who are not on your payroll if you supervise these employees on a day-to-day basis. If your business is organized as a sole proprietorship or partnership, the owner or partners are not considered employees for recordkeeping purposes.

Here is a link for more information: https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.31

   

An employee has a job related injury but does not seek medical attention until 2 days after the incident and consequently is hospitalized and treated for  in patient care. Is this injury reportable

1  

Yes, it is a reportable injury due to it being work-related and resulting in an inpatient hospitalization. That the employee did not seek medical attention immediately does not relieve the employer of OSHA's record-keeping requirements once medical treatment beyond first aid is provided.

Here are some links for more information:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9638&p_table=STANDARDS

https://www.osha.gov/laws-regs/standardinterpretations/2007-02-06-1

   

I know it would be recordable but would it also be reportable - What about OSHA 1904.39(b)(6)? and what if the employee waited one month after the work related incident and was hopsitalized?

4  

David, you make a good point, 1904.39(b)(6) gives a 24 hour timeframe following the incident in which the in-patient hospitalization would be reportable. However, if the employee did not report the incident immediately, the clock would not start until the employer was made aware of the incident which could mean that the hospitalization is reportable. I suggest that you discuss with your legal counsel to be certain that the correct action is taken as there are potential consequences for both underreporting and overreporting.

 

1904.39(b)(6)

What if the fatality, in-patient hospitalization, amputation, or loss of an eye does not occur during or right after the work-related incident? You must only report a fatality to OSHA if the fatality occurs within thirty (30) days of the work-related incident. For an in-patient hospitalization, amputation, or loss of an eye, you must only report the event to OSHA if it occurs within twenty-four (24) hours of the work-related incident. However, the fatality, in-patient hospitalization, amputation, or loss of an eye must be recorded on your OSHA injury and illness records, if you are required to keep such records.

1  

Would like to know if a muscle strain reported by an employee - he pulled a muscle in his back while using the washroom for personal need (Toilet) while at work.

is this considered a work related injury as per OSHA?

   

According to 29 CFR 1904.5, an injury is work-related if it occurs in the work environment. The work environment is “the establishment and other locations where one or more employees are working or are present as a condition of their employment.”

As long as the injury occurred during the employee’s assigned working hours, including lunch or breaks, the injury is considered work-related.

Here is a link to CFR 1904.5 and a link to a letter of interpretation that addresses a scenario similar to yours.

https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5

https://www.osha.gov/laws-regs/standardinterpretations/2010-02-16

   

An employee had weld flash burn to the eyes.  The employee went to the emergency room during the shift on a Thursday did not return to work that day.  They also did not return to work on the follwoing Friday.   They did return to work the following Monday.   Is this recorded as an OSHA  recordable injury and a lost time injury?  Can it be both?

1  

If the employee did not return to work at the direction of a physician or licensed health care provider then it would be a recordable injury with days away from work. The number of days would be based on the physician's direction and you may have to include the weekend.

1  

Hi Can you give some examples for incidents that are recordable but not reportable.?

1  

Some examples of injuries that are recordable but not reportable are

  • a cut requiring stitches,
  • a muscle strain requiring time off or light duty (restricted work or transfer to another job)
  • a burn or infection for which a prescription medication is given (or non prescription medication directed to be used at prescription strength by a physician)

OSHA provides additional guidance on this subject here: https://www.osha.gov/recordkeeping/

   

An employee has a job related injuryand reported the same day, first aid was administered.  Then sought medical attention 34 days after the incident and consequently is hospitalized and treated for  in patient care. Is this injury reportable

   

Hello Jack. Thank you for your question.

Because the employee reported the incident right away 1904.39(b)(6) is clear on this: You must only report an in-patient hospitalization if it occurs within twenty-four (24) hours of the work-related incident. However, it must be recorded on your OSHA injury and illness records, if you are required to keep such records.

2  

If an employee gets a scratch and needs one bandaid, is that recordable?

3  

An employee fell on the ice, hit his head, taken by ambulance to the hospital, doctor said to take the next day off.  No restrictions (other than day off).  No meds.  Is this a recordable?

   

Hello, is it a recordable if the employee receives prescription medication? Or is it certain mlg that it becomes a recordable?

   

 Hi, if an incident happened during breaktime hours, is it recordable?

   

Can you give me sample's of what is not reportable to Ohsa.

   

If an employee is in a crosswalk and hit by a car that ran a stop sign, is it recordable?  The employee in question was on the clock at the time of the incident.  He was not seriously injured but did have 2 missed work days for doctor's visits to confirm there were no serious injuries.

3  

Question no one can answer. Man kneels down on a pebble and his knee hurts like hell and swells up. That was on a Friday. Monday he was ok Tuesday he wants to go to the doctor. Doctor does an xray and small exporitory insission. Closed it with a butterfly bandage. Gave him a scrip for Ibprofin because of the insision. You tell me was there an injury in the first place? If there is no injury is it a recorable? Answer correctly because I am useing your expertice to write my report.

5  

Script not scrip, incision not insission, Ibuprofin, recordable not recorable, expertise not expertice, exsploratory not exporitory, using not useing...

As a safety professional. Proper report writing is paramount. Utilizing proper grammar would be where I start.

Also,  there are a few major details you left out.

1.Did this event occur at work?

2. Ibuprofin is given for pain not incisions. Pain due to the incision or original injury.

3. The initial injury was in fact an injury in the first place. Which resulted in a DART.

This was in fact easily answered.

 

2  

Where to start? You can't even come close to a safety professional. You said this was easily answered. LOL you didn't answer it. I guess it was easy LOL. A Pro would not use the entire question to belittle someone. Everyone put your hands together for this very young person who can spell. You knew what I said but used the opportunity to criticize a me. Yea your a pro. You also asked it it happened at work. That was your first most important question. Another tell tell sign your not a pro. I wouldn't even waist my time with this if it had happened on vacation MR. low IQ. Your second question was Ibuprofen is given for pain. Wrong again it is given for swelling. It was swelling that caused the pain. And if you didn't have all the facts why did you answer the third question saying it was a DART? So there we are. This is what happens people when you let kids in the room. They truly thing they have all the answers. I sure wish I had time to read all these questions. Grow up get a job and keep yourself busy. In a business where people do not get awards and trophies my room is filled with them from being the best. Normally I use so many curse words but now I know they are kids in the room I will refrain. Ok we have come to the end and now I will let everyone know the very best part and the reason I wrote this. You might not want to throw rocks and live in a glass house. That means do not criticize me for spelling when in the same paragraph you misspelled a word. You do that to get a laugh or show off not teach. So let me be the first to tell you how to spell Ibuprofen is how you spell it dick head. Everyone is now laughing at Sorry Cotten LOL

1  

Ummmm. it is Cotton. Not Cotten.

When asking in regards to a safety question. You need to clarify if the accident happened at work. No assumptions should be made.

Nice, eloquent and professional response though Mr. Miller.

2  

What is the outcome if an employer accuses an employee of damaging a wall with forklift with zero witnesses subjects him to a blood drawn drug test and reports it to osha?

1  

Hi Olivia, Was the employee injured or did this lead to an incident? If there was an incident it does need to be reported to OSHA. 

2  

If your incidents are at zero (0) would the dart rate be zero? Please advise

1  

An employee fell and hit her ribs on one of our machines she was sent to the er to get checked because she was in pain is that a recordable?

1  

Hi Sylvia - Yes, that's an example of a recordable incident. 

1  

An employee  doesn't feel well and is taken by ambulance due to a medical condition (not work related) is this reportable ? 

1  

Hi Cindy, 

According to the general guidelines, if the worker was on the job and taken to the hospital for a condition, it should be reported. If you're ever in doubt, you should contact OSHA directly to explain the circumstances of the incident. 

1  

An employee was hit in the mouth by a gate that was popped off of a part.  She did in fact go to the hospital to get checked out.  She had Dermabond applied to her lip.  Since it was just liquid band aid, does this qualify as a recordable

   

Hi Stacey, Thanks for your question. A good rule of thumb to go by is to contact OSHA if you're unclear on the rules. In this case, the employee did seek medical attention at a hospital, which should be reported. Thankfully her injury wasn't worse. 

   

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