Explore the sections in this guide
The short answer
No. Recording injuries and illnesses, reporting severe events to OSHA, and electronically submitting annual data are separate obligations.
Many employers with more than 10 employees must keep OSHA injury and illness records; certain industries have exemptions. Electronic submission depends on establishment size and industry. An exemption from routine recordkeeping does not automatically remove severe-event reporting duties.
A practical example
The office keeps an internal incident list and assumes nothing else is required. Determine which recording, reporting, and submission duties apply instead of treating that list as the answer.
Your next steps
- Confirm establishment size and industry applicability.
- Assign owners for each applicable duty.
- Use the official guidance and forms for the relevant requirement.
One incident can trigger several independent questions
| Record or decision | What it addresses | What to check |
|---|---|---|
| Internal notice | Company notification and investigation | Use the employer’s process. |
| Recordability | Whether the event meets recording criteria | Apply the OSHA criteria to the facts. |
| Severe-event report | Whether prompt notification to OSHA is required | Evaluate separately from routine recording. |
| Annual submission | Whether the establishment submits data | Check establishment size and industry requirements. |
Insurance paperwork does not decide OSHA recordability
A claim status, deductible, or internal preventability category serves a different purpose. Determine work-relatedness and the applicable recording criteria using the facts and official guidance. The same event can be described differently in company, insurer, DOT, and OSHA records because those systems ask different questions.
Example: the incident starts as a minor-injury notification
The office receives an initial report and later learns that the treatment or outcome changed. Reassess the applicable recording and reporting questions using the updated facts. Do not assume the first classification remains correct simply because the internal form was already closed. Identify who monitors additional information and who can act on a time-sensitive requirement.
Review the establishment rather than copying another facility’s answer
Workforce size, industry, and the applicable criteria affect routine records and electronic submission. A determination made for a different facility may not establish the answer for yours. Keep the establishment information and the basis for any exemption or submission decision together.
Deadlines to put in the incident-response procedure
Federal OSHA requires reporting a work-related fatality within eight hours, and an inpatient hospitalization, amputation, or loss of an eye within 24 hours. Delayed knowledge has its own timing rules. A fatality is reportable when it occurs within 30 days of the incident; the other listed outcomes must occur within 24 hours of the incident. Inpatient admission for observation or diagnostic testing alone does not meet the hospitalization reporting definition.
For fleets, a critical exception concerns motor-vehicle accidents on public roads outside construction work zones: §1904.39 does not require the severe-event report, but recording can still apply. Construction work-zone crashes have different reporting treatment. Do not apply the highway exception to a yard or facility incident. Reporting criteria, exceptions, and methods.
The annual calendar
- February 1–April 30: post the certified Form 300A summary where required, including a zero-case year.
- March 2: covered establishments submit the prior year’s required data electronically. This is separate from posting. Check establishment size and industry with the OSHA ITA coverage guidance.
- Five years after the covered year ends: retain the required records under §1904.33; update the retained log as required.
The small-employer routine-recordkeeping exemption uses company-wide employment during the preceding calendar year. Electronic-submission thresholds use establishment size and industry. Those are different tests. Annual summary requirements.
Evaluate recording and reporting separately
A work-related case may need evaluation for OSHA recordability even when it does not trigger immediate severe-injury reporting. Conversely, start the severe-event reporting assessment immediately rather than waiting for the annual log process. Consider work-relatedness, the applicable criteria and any exceptions using the actual facts. A workers’ compensation claim decision does not by itself settle the OSHA classification.
Document how the establishment reached its decision
Keep the relevant event date, when the employer learned of the event, treatment information and the basis for classification. Apply privacy-case procedures when required. Electronic submission depends on the establishment’s size and industry criteria, which are separate from a business’s obligation to maintain records. Assign the submission task to the correct establishment and verify acceptance. A saved spreadsheet is not proof that the required electronic submission succeeded.
Official source
Confirm applicability, exceptions, and current requirements for your operation. This is a focused summary.
