No matter how safe an organization is, incidents still may occur. But not all of these will rise to the same level of severity and consequence, even if they could be technically classified as an ‘incident’ according to established regulations.
This is why a firm grasp on what does—and does not—qualify as OSHA Recordable or Reportable Incident becomes essential for employers trying to protect their workforce and stay compliant with labor laws. In this post we’ll cover everything safety teams need know about identifying which type of incident they are dealing with, including pertinent definitions and helpful illustrative examples. Let’s get started!
Basic Terms to Understand with OSHA Incidents
There are three main terms used with OSHA records. You will learn more about each one later, but here is what they mean:
- Recording: the process of tracking any on-the-job injury or illness. Each organization must complete and maintain multiple forms and logs, with each form requiring unique information to be provided.
- Reporting: Notifying OSHA of certain outcomes from occupational incidents, such as death. Incidents must be reported within a certain time frame by OSHA guidelines.
- Submitting: Similar to recording, but this requirement doesn’t apply to every employer. Some employers are required to electronically submit specific injury and illness forms to OSHA each year.
Who Needs to Record Injuries?
Under 29 CFR 1904, any employer who is covered by the Occupational Safety and Health Act and has 11 or more employees must keep OSHA record for injuries and illnesses. Employers with 10 or fewer employees and organizations in certain low-hazard industries are not required to keep such records.
Some employers are not covered by the federal OSHA regulations. There are 26 states and 2 U.S. territories that have their own OSHA-approved State Plan. Even though these plans may be different from the federal regulations in some ways, OSHA has said that the “State plans must have occupational injury and illness recording and reporting requirements that are very similar to the requirements in this part.”
If an employer has a fluctuating amount of employees throughout the year, if they ever have a maximum number over 11 then they are required to maintain OSHA records for injuries and illness.
What Makes Something Recordable?
Each incident must be evaluated to determine if it is recordable or not. OSHA has provided a list of conditions which must be met before an incident can be recorded. Simply put, a recordable incident is a work-related injury or illness that results in any of the following:
- Fatality
- Loss of consciousness
- Day(s) away from work
- Restricted work activity or job transfer
- Diagnosis of cancer or chronic irreversible diseases
- Punctured eardrum
- Fractured or cracked bones
- Medical treatment beyond first aid
There are some things that must always be recorded, no matter what type of treatment was used or what the result was (for example, death or days away from work). These include:
- Hearing loss
- Medical removal
- Needlestick injuries
- Tuberculosis
Remember that each incident that you record must be a new case. This means that the employee must:
- Has not had an injury or illness of the same type before that affects the same part of the body.
- Previously experienced a recorded injury or illness of the same type that affected the same part of the body but had recovered completely from the previous injury or illness
What makes an injury or illness reportable?
Most recordable injuries will not fall under a reportable incident. The only time these injuries and illnesses will need to be reported is when submitting the yearly OSHA logs.
However, there are certain instances where an injury or illness needs to be reported immediately to OSHA. Depending on the severity of the incident, you may only need to report it within 8 hours or up to 7 calendar days.
Any occupational incident that results in:
- a fatality or a severe injury
- in-patient hospitalization
- amputations
- the loss of an eye
All of these must be directly reported, either to the nearest OSHA Area Office, to the 24-hour OSHA hotline, or via the online reporting form.
Timeline for Reporting
The timeline for reporting depends on the severity of the incident. For fatalities, all employers must report within 8 hours of learning about it. For in-patient hospitalization, amputations, or loss of an eye, you have up to 24 hours after learning about it to report these incidents.
Unlike the majority of documentation requirements, OSHA requires all employers, no matter the size or other factors, to report these specific types of accidents.
In addition, remember that employers may not need to report an incident of illness or injury to OSHA in the event that:
- Resulted from a motor vehicle incident on a public street or highway (except in a construction work zone)
- Occurred on a commercial or public transportation system
- Involved hospitalization for diagnostic testing or observation only
In such instances, the injury or illness should still be documented on the appropriate OSHA logs; they don’t need to be reported directly to OSHA.
How to Document Occupational Incidents
There are three different kinds of logs that need to be completed and maintained by all applicable organizations. The names of the logs can be easily confused, but here is a simple breakdown of the function of each.
Also known as an Injury and Illness Incident Report form, this contains any injury deemed to OSHA recordable. This form will list the extent and severity of an injury or illness and medical information.
Labeled as an Injury and Illness Incident Report form, this document is utilized to capture any injury or illness regarded to be recordable by OSHA. This form outlines the extent and severity of an injury or illness alongside pertinent medical details.
It is essential to document any incidents within seven days of learning about any injuries or illnesses. This form should not be sent to OSHA, however it must be kept at your worksite for a minimum of five years.
The OSHA 300 Log is the next form that must be completed, containing essential information such as employee details and whether or not an incident resulted in death, days away from work, a job transfer – or any other outcomes.
In the same way as Form 301, employers must also retain a 300 Log at their job site for five years. Although it is not sent to OSHA, they may need to present a copy of this log upon request during an inspection.
In 2019, OSHA upgraded the recordkeeping regulation for applicable organizations so that only a single form—the OSHA 300A—is now required. This document summarizes all work-related incidents over the course of one year, simplifying and streamlining administrative processes.
The OSHA 300A form needs to be stored at the worksite for five years and signed by an executive in order to remain compliant. Furthermore, this form must also be displayed from February 1st until April 30th each year. Failing to adhere to these guidelines can result in hefty fines or potentially more serious consequences.
Conclusion
In conclusion, OSHA requires employers to report all fatalities, in-patient hospitalizations, amputations, and losses of an eye that occur within their organization. Documentation must also be completed on the correct forms and stored at the worksite for five years.
Adhering to these regulations can ensure that you remain complaint with OSHA standards and avoid any penalties or fines.
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