1. Determine Whether the Occupational Accident Is Recordable
An occupational accident does not automatically require an OSHA 300 or 301 entry. Employers subject to Part 1904 first ask whether the case is work-related, new, and covered by OSHA’s recording criteria.
Recordability Depends on the Case and Employer
- Federal recordkeeping rules include partial exemptions based on employer size and certain industry classifications.
- A work-related case may be recordable if it involves days away, restricted work, job transfer, medical treatment beyond first aid, loss of consciousness, or another qualifying result.
- Broader reporting procedures can also be reviewed through workplace compliance.
Recordable Cases Use OSHA Forms
- OSHA Form 300 logs qualifying work-related injuries and illnesses.
- Form 301, or an equivalent form, provides incident-level information for each recordable case.
- An employer exempt from routine recordkeeping may still have a duty to report a qualifying fatality or severe injury.
2. Recordable Cases Generally Have a Seven-Day Deadline
Under 29 CFR 1904.29, employers required to keep OSHA records generally have seven calendar days after receiving information that a recordable injury or illness occurred to complete the required entries.
The Deadline Runs from Receipt of Information
- The employer enters the case on the OSHA 300 Log within the seven-day period.
- The OSHA 301 Incident Report, or an equivalent form, follows the same general recording deadline.
- Later information may require review or updating of an existing entry under OSHA’s recordkeeping rules.
Incident Records Should Reflect the Facts
- Dates, injury descriptions, work status, and treatment information should match the available information.
- Medical and employment facts can affect whether the case meets a recording criterion.
- A serious event may also lead to a workplace investigation involving witnesses, records, and safety conditions.
3. Severe Events Trigger Faster OSHA Reporting
Some work-related events require direct notice to OSHA in addition to any applicable recordkeeping duty. Section 1904.39 sets different reporting periods for fatalities and specified severe injuries.
Fatalities Carry an Eight-Hour Rule
- A reportable work-related fatality generally must be reported within eight hours.
- The reporting rule applies when the death occurs within 30 days of the work-related incident.
- If the employer learns later of a reportable death or its work-related nature, the eight-hour period runs from that knowledge as provided by the rule.
Specified Severe Injuries Carry a 24-Hour Rule
| Reportable Event | OSHA Reporting Period |
|---|---|
| Work-related fatality | Within 8 hours |
| In-patient hospitalization | Within 24 hours |
| Amputation | Within 24 hours |
| Loss of an eye | Within 24 hours |
Work-related fatality
- OSHA Reporting PeriodWithin 8 hours
In-patient hospitalization
- OSHA Reporting PeriodWithin 24 hours
Amputation
- OSHA Reporting PeriodWithin 24 hours
Loss of an eye
- OSHA Reporting PeriodWithin 24 hours
For hospitalization, amputation, or loss of an eye, the event must occur within 24 hours of the work-related incident for section 1904.39 reporting to apply.
4. Annual Posting and Electronic Submission Are Separate Duties
The OSHA 300A posting rule and electronic submission rule serve different purposes. Employers should check each requirement separately rather than treating electronic submission as a substitute for workplace posting.
The 300A Summary Has an Annual Posting Period
- Employers required to keep Part 1904 records review the annual log and prepare and certify the OSHA 300A Summary.
- The summary generally must remain posted from February 1 through April 30 of the following year.
- Electronic access does not replace the required workplace posting of Form 300A.
Electronic Submission Depends on Size and Industry
- Certain establishments with 20–249 employees in Appendix A industries submit Form 300A data electronically.
- Establishments with 250 or more employees that must keep Part 1904 records also submit Form 300A data.
- Certain establishments with at least 100 employees in Appendix B industries also submit specified Form 300 and 301 data by March 2.
5. State Reporting Duties Follow a Separate Track
OSHA reporting does not replace workers’ compensation notices or other filing duties created by state law. Employers also need to determine whether federal OSHA or an OSHA-approved State Plan governs the establishment.
Workers’ Compensation Deadlines Come from State Law
- State law may require notice to a workers’ compensation insurer, agency, or another designated recipient.
- Those deadlines should not be calculated from OSHA’s seven-day, eight-hour, or 24-hour periods.
- Benefits and claims issues may overlap with industrial accident compensation requirements.
State Plans May Add Reporting Requirements
- Workplaces under an OSHA-approved State Plan follow that plan’s applicable regulations.
- State Plan recordability requirements must be substantially identical to federal Part 1904 requirements.
- Other reporting requirements may be supplemental or more stringent, so multi-state employers should check the governing program for each establishment.
6. Frequently Asked Questions
Does every workplace injury have to be reported directly to OSHA?
No. Direct reporting under section 1904.39 applies to specified work-related fatalities, in-patient hospitalizations, amputations, and losses of an eye. Other cases may require OSHA recordkeeping when the applicable criteria are met.
Does an emergency room visit automatically trigger the 24-hour OSHA rule?
No. OSHA defines in-patient hospitalization as formal admission to the in-patient service of a hospital or clinic for care or treatment. Admission only for observation or diagnostic testing does not meet that reporting definition.
When is OSHA electronic injury data due?
Covered establishments generally submit required electronic injury and illness information by March 2 of the year after the records were created. The forms required depend on establishment size and industry.
Can a state reporting deadline differ from OSHA rules?
Yes. An OSHA-approved State Plan may have supplemental or more stringent reporting requirements, while workers’ compensation notice and filing duties arise separately under state law.
7. Review Occupational Accident Reporting Duties with SJKP
SJKP’s attorneys can review the incident, OSHA recordability criteria, severe-event reporting requirements, annual recordkeeping duties, and the relationship between federal and state reporting systems. The firm can also assess which reporting rules and deadlines apply to the employer’s circumstances.
02 Oct, 2026
