BLS Survey Requests and OSHA Recordkeeping Data
If BLS sends you its Survey of Occupational Injuries and Illnesses, you must complete it, even if you are normally exempt from OSHA recordkeeping.
The short answer
If BLS sends you its Survey of Occupational Injuries and Illnesses, you must complete it, even if you are normally exempt from OSHA recordkeeping. BLS notifies selected employers in advance, and those employers keep records for the survey year.
BLS mail can surprise employers who assumed they had no routine filing work.
The rule in plain English
Two partial exemptions decide whether you keep routine OSHA injury records. A company with 10 or fewer employees at all times during the previous calendar year is exempt (29 CFR 1904.1), and the count is company-wide across all locations. An establishment in an industry listed in Appendix A to Subpart B is exempt (29 CFR 1904.2), and that test is applied establishment by establishment using its NAICS code. Neither exemption covers severe injury reporting: every employer reports a fatality within 8 hours and an in-patient hospitalization, amputation, or loss of an eye within 24 hours (29 CFR 1904.39). An exempt employer must also keep records if OSHA or BLS asks in writing.
How it plays out on site
Respond to covered BLS survey requests using accurate injury and illness data. Scope mistakes are expensive because they repeat every year: a wrong exemption means a missing log, a missing 300A, and sometimes a missed ITA submission. The fix is to answer each scope question with the right unit (company-wide headcount for the size exemption, the establishment's NAICS code for the industry exemption) and to write the answer down.
HR usually holds the headcount, leave, and restriction paperwork that recordkeeping depends on, so the handoff to safety matters as much as the rule.
The common mistake
Teams confuse BLS survey reporting with OSHA ITA submission.
Scope sits upstream of everything else: whether you keep a log decides whether you certify and post a 300A, and whether you must submit to the ITA at all.
Edge cases
- The survey request can create obligations separate from ordinary assumptions.
- Part-time, seasonal, and temporary workers you employ count toward the 10-employee test.
Worked example
A 40-person dental group (partially exempt) receives a BLS letter in December saying it will be surveyed for the coming year. It keeps a 300 Log and 301s for that year and completes the survey from them. The ITA is a separate program, and the letter does not create an ITA obligation.
Checklist
- Confirm the request comes from BLS or its designee.
- Start keeping records for the survey year if you were exempt.
- Complete the survey from your records.
- Keep a copy with the year's records.
What to keep in the case file:
- Peak company-wide headcount for the prior year, with its source
- Each establishment's NAICS code and how it was chosen
- Any written notice from OSHA or BLS
- Your severe-injury reporting procedure, which applies regardless of exemption
Where 300log helps
300log keeps each establishment's NAICS code and industry description with its records, so exemption and ITA coverage checks start from the code you actually file under.
For a quick answer without an account, use the free ITA coverage checker.
Frequently asked questions
Can an exempt employer be asked to keep records?
Yes. OSHA or BLS can notify you in writing that you must keep records for a coming year, and then you must.
Does the 10-employee rule count all locations?
Yes. It uses peak employment for the whole company during the previous calendar year, including part-time, seasonal, and temporary workers you employ.
If we are exempt, do we still report serious injuries?
Yes. Fatalities must be reported within 8 hours, and in-patient hospitalizations, amputations, and losses of an eye within 24 hours, whether or not you keep records.
What is the difference between reporting and recording?
Recording means entering a case on your 300 Log. Reporting means notifying OSHA directly about a fatality or severe injury. They have different triggers, deadlines, and exceptions.
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.42: Requests from the Bureau of Labor StatisticsOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]29 CFR 1904.29: OSHA Forms 300, 300A, and 301Occupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.33: Retention and updatingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
Written and reviewed by the 300log Editorial Team. Guidance, not legal advice: confirm edge cases with OSHA or counsel.