The Occupational Safety and Health Act requires that certain employers prepare and maintain records of certain types of occupational injuries and illnesses each year. While the requirements vary based on employer size and industry, this guide provides a clear overview to help businesses understand their obligations, based on their size and industry.
General Reporting Requirements for All Employers
Every private employer must comply with OSHA's severe injury and fatality reporting requirements. These include:
- Fatalities: Report work-related fatalities (excluding vehicle accidents) within 8 hours.
- Severe Injuries: Report workplace injuries resulting in amputation, eye loss, or hospitalization (admitted to the hospital) within 24 hours.
Reports for these issues can be submitted through OSHA’s reporting website.
Additionally, the Bureau of Labor Statistics (BLS) may require businesses to participate in its annual survey of occupational injuries and illnesses. If selected, your business will receive a notice in December of the prior year and you are required by law to track workplace injuries and report them at the end of the following year, regardless of your employment size or industry grouping.
Understanding Small Establishment Exemptions
For establishments with fewer than 11 employees, maintaining OSHA Forms 300 and 300A is not required. OSHA defines an establishment as “a single physical location where business is conducted or where services or industrial operations are performed.” However, if your business operates multiple small establishments but collectively employs more than 11 people, you must comply with the OSHA 300 and 300A reporting requirements.
Industry-Specific Exemptions
Employers with more than 11 employees in certain industries may also be exempt from OSHA’s recordkeeping requirements. These exemptions are based on the North American Industrial Classification System (NAICS). A detailed list of exempt industries can be found at OSHA’s exempt industries table.
Categories of Employers Required to Submit Annual Reports
OSHA mandates annual electronic reporting for three specific categories of employers by March 2nd:
- Mid-Sized Establishments: Employers with 20–249 employees (at any time during the previous calendar year) in industries listed in appendix A must submit Form 300A annually through the OSHA Injury Track Application.
- Large Establishments: Employers with 250 or more employees (at any time during the previous calendar year), are required to keep records under OSHA’s guidelines and must submit Form 300A annually.
- Certain Industry Groups: Establishments with 100 or more employees (at any time during the previous calendar year) in industries listed in appendix B must submit Forms 300, 301, and 300A annually.
Three Key OSHA Forms for Recordkeeping
- OSHA 300: Log of Occupational Injuries and Illnesses.
- OSHA 300A: Summary of Work-Related Injuries and Illnesses.
- OSHA 301: Injury and Illness Incident Report.
These forms and completion instructions can be found in this package on OSHA’s website.
By understanding these requirements and keeping accurate records, employers can stay compliant and ensure workplace safety standards are met.