Recordable vs. Reportable: Understanding the Difference

With OSHA records, three main terms are commonly used, and they’ll be used throughout this article. You’ll learn more about each later on, but here are the basics.

Recording is simply the act of tracking an on-the-job injury or illness. Multiple forms and logs need to be filled out and maintained by each organization, with different details required of each one.

Reporting means notifying OSHA of certain outcomes from occupational incidents, such as a death. These types of incidents must be reported within a certain time frame, depending on the occurrence.

Submitting is similar to recording, in that the requirement doesn’t apply to all employers.

However, for those who fall within the restrictions, a specific injury and illness form needs to be electronically submitted to OSHA each year.

Who needs to record injuries?

Under 29 CFR 1904, any employer covered by the Occupational Safety and Health Act of 1970 with 11 or more employees must maintain OSHA injury and illness records. Employers with 10 or fewer employees and organizations in certain low-hazard industries are partially exempt from keeping such records.

Within many smaller organizations, employee numbers may fluctuate throughout the year. In these instances, employers should review their maximum employment numbers. If at any time during the year you have more than 10 employees, you’re required to record safety incidents, unless you’re in an exempt industry.

Additionally, not all employers are covered by federal OSHA regulations. Currently, 26 states and two U.S. territories operate under an OSHA-approved State Plan.

Although these plans may differ from federal regulations in some aspects, OSHA has been clear in noting that “State Plans must have occupational injury and illness recording and reporting requirements that are substantially identical to the requirements in this part.”

What makes something recordable?

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

With regard to the last item, OSHA provides a detailed list of treatments it considers to be basic first aid. Because this list covers such a wide variety of treatments, such as nonprescription medications, simple wound coverings, and even hot or cold therapy, this will likely be enough to treat many less severe incidents.

If basic first aid is all that is needed to treat an injury, that incident doesn’t need to be noted in your recordkeeping logs.

On the other hand, if anyone – no matter if that person is a medical professional or not – has to administer a “medical treatment” for an injury or illness, the incident is required to be recorded.

The list of things OSHA considers to be medical treatment in these instances includes:

• Nonprescription medication used at prescription strength
• Stitches and staples to close wounds
• Rigid devices for support
• Physical therapy or chiropractic treatment
• Certain vaccines, such as those for rabies or hepatitis B

Additionally, if a health care professional recommends one of these treatments and the affected employee doesn’t follow-up on that recommendation, the incident still must be recorded.

There are also specific cases that must be recorded, regardless of the type of treatment applied or the physical result (e.g., death or days away from work) may be. They are:

• Hearing loss
• Medical removal
• Needlestick injuries
• Tuberculosis

One final thing to keep in mind is that each recorded incident must be a new case. According to OSHA, an injury or illness can be considered a new case if the employee:

• Has not previously experienced a recorded injury or illness of the same type 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.

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