Injury and illness recordkeeping: Recordable vs. reportable

With the new year upon us, it is time for employers to wrap up 2025 recordkeeping and reporting obligations, including those for workplace injuries and illnesses. Accurate recordkeeping and timely reporting help ensure employers fulfill their obligations under OSHA’s Recording and Reporting Occupational Injuries and Illnesses regulations at 29 CFR 1904. It is also a good time to review the difference between what is “recordable” and what is “reportable” because having a thorough understanding of this crucial distinction can help avoid OSHA enforcement actions.

“Recordable” involves maintaining detailed logs of work-related injuries and illnesses, and in certain instances, submitting this recorded data to OSHA. “Reportable” refers to the process of promptly notifying OSHA about specific, serious incidents, such as fatalities, severe injuries, or in-patient hospitalizations.

What is recordable?

OSHA requires employers with 10 or more full-time employees to maintain a yearly record of work-related injuries and illnesses using the OSHA 300-Log of Work-Related Injuries and Illnesses form, which captures detailed information about each recordable incident, including the nature of the injury or illness, the affected employee, and a brief description of what happened, including the type of injury or illness. The employer must enter each injury or illness on the OSHA 300 log within 7 calendar days of receiving information that a recordable event has occurred.

Recordable events

Generally speaking, any of the following injuries or illnesses need to be recorded on the OSHA 300 log:

• Any work-related fatality.
• 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 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.

There are also special recording criteria for work-related cases involving needlesticks and sharps injuries; medical removal under the medical surveillance provisions of an OSHA regulation; hearing loss; and tuberculosis.

Not all injuries or illnesses need to be recorded, though. OSHA has published a list of first aid measures at 29 CFR 1904.7(b)(5)(ii) that do not have to be recorded. Many companies find this list useful because they can either hire in-house medical personnel or send employees to dedicated occupational clinics to provide first aid care that is equivalent to medical treatment. The advantage being that first aid care does not need to be recorded, and the employee receives proper treatment.

Other recordkeeping forms

In addition to the OSHA 300 form, which is the actual log of injuries and illnesses, there are two other forms used to record work-related injuries and illnesses.

• The 301-Injury and Illness Incident Report form is used to record information on how each injury or illness case occurred.
• The 300A-Summary of Work-Related Injuries and Illnesses form serves as the summary of work-related injuries and illnesses.

Electronic submission to OSHA

The following establishments are required to submit information from the OSHA 300A form to OSHA electronically each year:

• Establishments that had 250 or more employees at any time during the previous calendar year and are required to maintain injury and illness records.
• Establishments classified in designated industries listed in Appendix A to 29 CFR 1904.41 with at least 20 but fewer than 250 employees. Appendix A includes agriculture, forestry, fishing, and hunting; utilities; construction; manufacturing; wholesale trade; and a number of other industries.

Establishments with 100 or more employees in designated industries under Appendix B to Subpart E of 29 CFR 1904 must also electronically submit to OSHA detailed information from the OSHA Form 300 Log and the OSHA Form 301 Incident Report.

All submission must be done via OSHA’s online Injury Tracking Application by March 2 each year.

What is reportable?

OSHA, under 29 CFR 1904.39, requires employers to report any workplace incident that results in a fatality, in-patient hospitalization, amputation, or loss of an eye. All employers are required to notify OSHA within 8 hours after an employee’s work-related death, or within 24 hours when an employee suffers a work-related in-patient hospitalization, amputation, or loss of an eye.

If the fatality occurs more than 30 days after the work-related accident, or the in-patient hospitalization, amputation, or loss of an eye occurs more than 24 hours after the work-related accident, employers do not have to report to OSHA but must record the worst outcome of any case. Therefore, if the outcome or extent of an injury or illness changes after you have recorded the case, you must update your OSHA 300 log.

Posting in the workplace

At the end of each calendar year, the OSHA 300A form must be completed and certified by a company executive as correct and complete and posted in the workplace where notices to workers are usually posted. It must be posted by February 1 and remain posted until at least April 30.

Takeaways

OSHA recordkeeping and reporting doesn’t have to be complicated, but it must be done right to avoid confusion and OSHA enforcement actions. To do so requires an understanding of the distinction between “recordable” and “reportable,” as well as the difference between an electronic submission of OSHA 300 form data and a reportable incident.

Most recordable injuries are not reportable, and mixing up the terms can cause over-reporting of minor injuries or under-reporting of serious incidents. Remember, you need to record the most serious outcome for each case.

The electronic submission of OSHA 300 form data is a scheduled record upload to OSHA. A reportable incident is a prompt notification to OSHA of a fatality or other severe outcomes. One does not cancel out or replace the other.

This is the perfect time of year to sharpen your understanding of these key terms, review your records and correct mistakes, and ensure accurate recordkeeping and timely reporting going forward.