OSHA runs two systems. Reporting means calling a serious event in to OSHA on a deadline. Recordkeeping means logging, posting and retaining. Most lost points come from treating them as one.
Reporting: 8 hours against 24 hours
- Within 8 hours after the death of any employee from a work-related incident, report the fatality to OSHA.
- Within 24 hours after an in-patient hospitalization of one or more employees, an employee's amputation, or an employee's loss of an eye from a work-related incident.
Swapping 8 hours and 24 hours is the standard error. One hospitalized employee triggers the 24-hour report; there is no three-employee threshold.
Apply it: an amputation at 3:00 p.m. Friday must be reported within 24 hours. Holding it for a Monday safety summary misses the deadline by roughly two days. Report first; the 300 Log entry and investigation follow.
Recording criteria
Recordable if it results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness, or is a significant injury or illness diagnosed by a physician or other licensed health care professional. Not every report is recordable, there is no three-day minimum, and a state compensation outcome does not decide it.
Posting, retention, submission
- Post the annual summary Form 300A no later than February 1 of the following year, through April 30. Post the summary, not the individual 301 Incident Reports.
- Retain the 300 Log, privacy case list, annual summary, and 301 forms for five years following the end of the calendar year they cover.
- Establishments required to submit electronically must provide all required information by March 2 of the year after the year covered; the Injury Tracking Application window runs January 2 to March 2. February 1, April 30 and March 2 are all real OSHA dates - keep each on its own obligation.
The small-employer trap
An employer with 10 or fewer employees at all times during the last calendar year need not keep OSHA injury and illness records unless notified in writing by OSHA or the BLS. The reporting duty still applies to every employer covered by the OSH Act - fatalities, hospitalizations, amputations and eye losses.
Maximum penalty for a willful or repeated violation: $165,514 per violation.