Summary
In short
- Under 29 CFR 1904, an injury is recordable if it results in death, days away, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness, or if a licensed health care professional makes a significant diagnosis.
- Recording and reporting are different obligations: a fatality must be reported to OSHA within 8 hours, and an in-patient hospitalisation, amputation or loss of an eye within 24 hours, regardless of what happens on the log.
- Recordable cases must be entered on the OSHA 300 log within 7 calendar days of learning of them, and the 300A summary must be posted from 1 February to 30 April of the following year.
- First aid is defined by a closed list in 1904.7(b)(5)(ii), so treatment not on that list is medical treatment even if it feels minor, which is the most common recordability error.
- Records must be retained for five years following the calendar year they cover, and the 300 log must be updated as new information changes a case.
- A near miss with the same energy and the same exposure is the same event with a better outcome, which is why serious near misses deserve the same investigation depth as injuries.
What it is
What it is
What is a workplace incident report?
A workplace incident report is the first record of an unplanned event that caused, or could have caused, injury, illness, damage or loss. It documents the facts of the event rather than its causes, and it is the source record from which recordability, regulatory reporting and investigation decisions are made.
What makes an injury OSHA recordable?
Under 29 CFR 1904, a work-related injury or illness is recordable if it results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. It is also recordable if a physician or other licensed health care professional makes a significant diagnosis such as a fracture or a punctured eardrum.
How quickly must a fatality be reported to OSHA?
Within 8 hours of the employer learning of a work-related fatality. An in-patient hospitalisation, amputation or loss of an eye must be reported within 24 hours. These reporting deadlines are separate from, and much shorter than, the recording obligation on the OSHA 300 log.
When to use it
When to use it, and when not to
The instinct is to reserve the incident report for injuries. That produces a record set that measures outcomes rather than exposure, and a trend line that improves whenever reporting gets worse.
Use it for
- Any unplanned event causing injury, illness, damage or loss, however minor the outcome appears at the time
- A near miss with the energy and exposure to have caused a serious injury, scored on potential rather than what actually happened
- Property or equipment damage with no injury, which frequently shares a cause with events that do injure someone
- An environmental release, spill or exceedance, which usually needs a regulatory notification of its own as well
- A security or aggression incident affecting a worker, including events involving members of the public
Not for
- The investigation itself, including cause analysis, which belongs in a separate record so facts and conclusions do not blur
- A hazard nobody was exposed to yet, which belongs in the hazard register rather than the incident log
- A quality nonconformance with no safety dimension, which follows the nonconformance route
- Routine equipment faults found during inspection, which are maintenance work orders
- Grievances or conduct matters, which have their own confidential process
Standards
What it is built against
This template is the source record. It does not itself make the recordability decision, but it must capture everything that decision depends on.
| Clause | Requirement | Where it lands |
|---|---|---|
| 1904.4 | Recording criteria for work-related injuries and illnesses | Injury and treatment detail |
| 1904.5 | Determination of work-relatedness, including the exceptions | Circumstances, location, activity |
| 1904.7 | General recording criteria: death, days away, restricted work, transfer, medical treatment, loss of consciousness | Outcome and treatment |
| 1904.7(b)(5)(ii) | Closed list defining first aid, distinguishing it from medical treatment | Treatment given |
| 1904.29 | Forms 300, 300A and 301, and the 7-calendar-day entry requirement | Recordability outcome |
| 1904.32 | Annual summary preparation, certification and posting 1 February to 30 April | Downstream |
| 1904.33 | Retention and updating of records for five years | Retention |
| 1904.39 | Reporting fatalities within 8 hours; hospitalisation, amputation or eye loss within 24 hours | Regulatory notification |
| WorkSafeBC OHSR 3.4 | Employer investigation of incidents, including preliminary and full reports | Investigation handoff |
What it does not cover
- The investigation itself, including cause analysis, which belongs in a separate record so facts and conclusions do not blur.
- The recordability determination, which is a decision made from this record and should be logged with its reasoning.
- The OSHA 300 log and 300A summary, which are statutory forms with their own certification and posting rules.
- Corrective actions, which need owners, dates and effectiveness verification of their own.
- Workers compensation claim submission, which runs on the insurer's timetable, not the regulator's.
Filling it in
Filling it in well
The value of an incident report is set in the first hour. After that, the scene changes, people talk to each other, and recollection converges on a shared version that is tidier than what happened.
The report captures facts: time, place, task, equipment, people, conditions, sequence, outcome. Cause belongs in the investigation. Mixing them produces a record that leads the analysis and closes off lines of enquiry before anyone has looked. A first report that already names a cause is usually a first report that names the injured worker.
Photographs, positions, guard state, housekeeping, lighting, the actual tool in use. Within an hour the spill is mopped, the guard is back on and the offcut is in the bin. Nothing recovers that later, and the absence of it is what makes an investigation two weeks later feel like archaeology.
Work-relatedness is presumed for events occurring in the work environment, but 1904.5(b)(2) lists the exceptions, covering things like eating personal food, personal tasks outside working hours, personal grooming, self-medication for a non-work condition, and motor vehicle accidents in parking lots during commuting. Record the facts that bear on which applies rather than the conclusion.
An unguarded machine that nearly took a hand and one that did take a hand are the same failure with different luck. If your near miss reports are consistently thinner than your injury reports, the reporting system is measuring outcome rather than exposure, and the leading indicator you think you have is not one.
Audit findings
Common audit findings
Incident recordkeeping findings cluster around two things: cases that were never recorded, and records that were never updated.
| Finding | Clause | What fixes it |
|---|---|---|
| Recordable case not entered on the 300 log, or entered outside the 7 calendar day window. | 1904.29(b)(3) | Recordability decision triggered automatically from the report, with the seven-day clock started at first knowledge. |
| Medical treatment misclassified as first aid. | 1904.7(b)(5) | Structured treatment capture checked against the closed first aid list rather than a free-text note. |
| Fatality or hospitalisation not reported within the 8 or 24 hour deadline. | 1904.39 | Severity flag on the report that raises an immediate notification task with the deadline visible. |
| 300A summary not certified by a company executive, or not posted for the full period. | 1904.32 | Annual task with the certifying role named and the posting window tracked to closure. |
| Case not updated when days away or restriction counts changed. | 1904.33(b) | Open case status until the outcome is final, with day counts maintained rather than entered once. |
| Records not retained for the full five years, or retained without the 301 detail. | 1904.33(a) | Retain 300, 300A and 301 together for five years following the year covered. |
| Work-relatedness decision recorded as a conclusion with no supporting facts. | 1904.5 | Capture location, activity, timing and the specific exception considered, so the decision can be re-examined. |
| Privacy concern cases listed by name on the 300 log. | 1904.29(b)(6) | Privacy case flag that substitutes the case description and holds the name on a separate confidential list. |
| First report already names a cause or a person at fault. | ISO 45001 cl.10.2 | Separate the fact record from the investigation record, and remove cause fields from the initial form. |
| Near misses reported at a fraction of the rate of injuries, with no serious-potential cases. | ISO 45001 cl.10.2 | Score potential severity independently of actual outcome, and route high-potential near misses into full investigation. |
Worked case
The first hour decides what the investigation can find
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By jurisdiction
How the duty differs by jurisdiction
Every jurisdiction requires incident recording, but they disagree about what counts and how fast you must tell someone. Multinational operations get caught by the reporting deadlines rather than the recording criteria.
29 CFR 1904
Prescriptive. Closed definitions of recordability and first aid, statutory forms, fixed deadlines.
Recordability turns on treatment and outcome rather than severity as felt by the worker.
Provincial OHS regulations; WorkSafeBC OHSR Part 3
Provincially enforced with employer investigation duties.
BC requires a preliminary investigation within 48 hours and a full report within 30 days, which is a materially different obligation from US recording.
RIDDOR 2013
Reportable categories defined by injury type and absence duration.
Over-seven-day absence is the key threshold, reported within 15 days. Specified injuries and dangerous occurrences are reported without delay.
Model WHS Act Part 3
Notifiable incidents defined as death, serious injury or illness, or dangerous incident.
Notification is immediate on becoming aware, and the incident site must be preserved until an inspector directs otherwise.
ISO 45001 cl.10.2
Management system requirement to report, investigate and take action.
Certification auditors look for the thread from event to verified effectiveness, not just the report.
Definitions
Definitions and key terms
- Recordable case
- A work-related injury or illness resulting in death, days away, restricted work or transfer, medical treatment beyond first aid, or loss of consciousness, or involving a significant diagnosis.
- First aid
- Treatment appearing on the closed list at 1904.7(b)(5)(ii). Anything not on that list is medical treatment for recordkeeping purposes.
- Work-related
- An event or exposure in the work environment that caused or contributed to the condition, or significantly aggravated a pre-existing condition, subject to the listed exceptions.
- Days away
- Calendar days the employee was away from work following the day of the injury, capped at 180 days for logging purposes.
- Restricted work
- Where the employee cannot perform routine job functions or work a full shift, recorded separately from days away.
- Reportable event
- A fatality, in-patient hospitalisation, amputation or loss of an eye, requiring direct notification to OSHA within 8 or 24 hours.
- Privacy concern case
- Case types, including certain injuries and illnesses, where the employee name must be withheld from the 300 log.
- High-potential near miss
- An event with no injury but with the energy and exposure to have caused a serious one. Investigated on potential, not outcome.
FAQ
Frequently asked questions
What makes an injury OSHA recordable?+
Work-relatedness plus any one of: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. A significant diagnosis by a physician or other licensed health care professional, such as a fracture or a punctured eardrum, is also recordable even without those outcomes.
What is the difference between recording and reporting?+
Recording means entering a case on the OSHA 300 log, which must happen within 7 calendar days of learning about it. Reporting means directly notifying OSHA of a severe event: a fatality within 8 hours, and an in-patient hospitalisation, amputation or loss of an eye within 24 hours. The two obligations are independent and the reporting deadlines are much shorter.
Is treatment first aid or medical treatment?+
First aid is defined by a closed list at 1904.7(b)(5)(ii). If the treatment given is on that list it is first aid; if it is not on the list it is medical treatment, regardless of how minor it seems. Wound closure with sutures, staples or adhesive is medical treatment, while butterfly or steri-strips are first aid. Prescription-strength medication is medical treatment even at a single dose.
How long must incident records be kept?+
Five years following the end of the calendar year the records cover, under 1904.33. That covers the 300 log, the 300A annual summary and the 301 incident reports. The 300 log must also be updated during that period as new information changes a case, such as a change in days away.
When must the OSHA 300A summary be posted?+
From 1 February to 30 April of the year following the year covered. It must be certified by a company executive as correct and complete before posting, and it must be displayed where employee notices are normally posted.
Should near misses use the same report?+
Yes, with severity potential scored separately from actual outcome. A near miss with the energy to cause a fatality warrants the same investigation depth as a serious injury. Using a lighter form for near misses reliably produces lighter investigations, which is how the same event recurs with a worse outcome.
The agents
What the agents do with it
The report is easy. What fails is everything hanging off it: the recordability call nobody made, the eight-hour clock nobody started, the corrective action closed without anyone checking it worked.
Captures the report at the point of the event on mobile, starts the recordability assessment, and raises the notification task with the regulatory deadline attached when severity crosses the threshold.
Holds treatment detail against the closed first aid list and tracks days away and restriction as the case develops, so the log stays current rather than being entered once.
Links the event to competency records for the task and surfaces whether required training was current at the time.
Keeps the case thread together from report through investigation to verified corrective action, and holds every write for approval.
This template lives in KnowSafe — safety and compliance. Incidents, hazards, permits, inspections and the critical controls behind them.
Meet KnowSafe→Sources
Sources
- 29 CFR Part 1904, Recording and reporting occupational injuries and illnesses
- 29 CFR 1904.7, General recording criteria, including the first aid list
- 29 CFR 1904.39, Reporting fatalities, hospitalisations, amputations and losses of an eye
- WorkSafeBC Occupational Health and Safety Regulation, Part 3, incident investigation
- RIDDOR 2013 and HSE reporting guidance (UK)
- ISO 45001:2018 clause 10.2, incident, nonconformity and corrective action