Recording an injury is not the same as reporting one, and being exempt from one does not exempt you from the other. That distinction carries most of this unit.
When an injury is recordable: 29 CFR 1904.7
The general recording criteria are death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness, plus a significant injury or illness diagnosed by a physician or other licensed health care professional.
- First aid alone is not recordable. A cut treated with a bandage and antiseptic, shift finished, no restrictions, no physician: not recordable, because no criterion is met. The rule requires treatment beyond first aid, so "recordable because first aid was administered" inverts it.
- Work-relatedness alone is not enough, and finishing the shift is not itself the test. Internal practices such as reporting to a supervisor or a safety committee near-miss review are not recording criteria.
The forms
- Form 300 is the log of work-related injuries and illnesses.
- Form 300A is the annual summary posted at the worksite.
- Form 301 is the incident report retained with the other records.
Posting and retention
- 29 CFR 1904.32: post Form 300A no later than February 1 and keep it posted until April 30. Not January 1 to March 1, and not starting March 2 — March 2 is the electronic submission deadline, not a posting date.
- 29 CFR 1904.33: retain the 300 Log, privacy case list, annual summary and 301 Incident Reports for five years following the end of the calendar year they cover. Not three years, not seven years from each entry, and not employment plus 30 years, which is the pattern for certain medical exposure records.
The partial exemption
An employer with 10 or fewer employees at all times during the last calendar year is partially exempt from routine recordkeeping. But 1904.39 still requires every covered employer to report fatalities, in-patient hospitalizations, amputations and eye losses. A company with 8 or 9 employees is not "fully exempt from OSHA paperwork and reporting," and the size-based exemption stands alongside the separate industry-based one.