Recordable vs. Reportable: Understanding the Difference

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What makes an injury or illness reportable?

Most work-related injuries and illnesses that occur may need to be recorded on the proper OSHA logs, but the majority won’t be reported directly to OSHA, other than during an annual submission. However, certain situations call for immediate action from the employer.

Any incident that results in a fatality or a severe injury – in-patient hospitalization, amputations or the loss of an eye – must be directly reported to the nearest OSHA area office, the 24-hour OSHA hotline or via the online reporting form.

Work-related fatalities must be reported within eight hours of learning about the death. All other severe injuries listed above must be reported within 24 hours. Unlike any of the recordkeeping restrictions, all employers under OSHA jurisdiction must report these types of incidents.

However, it’s important to remember that employers don’t have to report an incident to OSHA if the injury or illness:

• Resulted from a motor vehicle incident on a public street or highway (except in a construction work zone)
• Occurred on a commercial or public transportation system
• Involved hospitalization for diagnostic testing or observation only

In such instances, the injury or illness should still be documented on the appropriate OSHA logs; they don’t need to be reported directly to OSHA.

What gets submitted to OSHA?

Although the various OSHA forms – outlined in more detail below – include specific information about injuries and illnesses, and these forms must be maintained onsite and may be requested for an inspection, the good news is that the majority of organizations won’t need to submit data to OSHA.

As of 2017, the only establishments that must electronically submit data from their Form 300A are those with 250 or more employees and those with 20 or more employees in certain high-risk industries. In these cases, employers must use OSHA’s Injury Tracking Application portal to submit Form 300A data by March 2 for the previous calendar year.

One thing to note is that, for organizations that fall under the requirements for submitting data to OSHA, an Injury Tracking Application must be completed even if no injuries or illnesses occurred. In that case, zeroes would be reported, but this information must still be officially documented.

How to document occupational incidents

OSHA has different recordkeeping logs that need to be completed and maintained by all applicable organizations. The names of the logs are similar, so they can be easily confused, but here is a simple breakdown of the function of each.

Form 301: Also known as an Injury and Illness Incident Report form, this contains any injury deemed to be recordable by OSHA. This form will list the extent and severity of an injury or illness and medical information. Incidents must be documented within seven calendar days of learning about the injury or illness. This form doesn’t get submitted to OSHA, but it must be maintained at your worksite for five years.

OSHA 300 Log: This form must include incident information such as employee details and whether the incident resulted in death, days away from work, a job transfer or other outcomes. Similar to Form 301, the 300 Log doesn’t get submitted to OSHA, but must be maintained on the jobsite for five years. Employers may need to produce a copy of the 300 Log upon request during an OSHA inspection.

Form 300A: In 2019, OSHA updated the recordkeeping regulation so that applicable organizations need to submit only Form 300A, which serves as an annual summary of all work-related incidents. Much like the other OSHA forms, Form 300A must be kept at the worksite for five years. Additionally, the form also needs to be signed by a company executive and displayed in the office from Feb. 1 to April 30 each year.

Training to avoid recordable incidents

Although it may go without saying, training your entire workforce not only helps to minimize safety risks, it also means you may be less likely to have an on-the-job incident that needs to be recorded.

It’s never a wrong time to evaluate your current safety program – or implement a new one – to protect your employees and ensure you’re adhering to OSHA standards. Contact SafetySkills today to see how we can help you get a head start on improving your safety program.

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