OSHA Reporting vs OSHA Recording: Why the Rules Are Not the Same
Recording puts a case on your 300 Log within 7 days; reporting notifies OSHA within 8 hours of a death or 24 hours of a severe injury.
The short answer
Recording puts a case on your 300 Log within 7 days; reporting notifies OSHA within 8 hours of a death or 24 hours of a severe injury. Many cases are recorded but never reported, and every reported event that is work-related is recorded too, if you keep records.
The words sound similar but the deadlines and triggers are different.
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
Use reporting for specific severe events and recording for OSHA 300 Log criteria. 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.
As the safety manager you usually own the decision itself, so the most useful habit is writing down the fact each call rests on at the time you make it.
The common mistake
Teams often report an event and forget to update the recordkeeping packet.
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
- Some events are recordable but not reportable, and some reporting exceptions still leave recording duties.
- Part-time, seasonal, and temporary workers you employ count toward the 10-employee test.
Worked example
In one month a plant has a sprained ankle treated with a rigid brace (recorded, not reported), a worker admitted to hospital overnight after a fall from a platform (reported within 24 hours and recorded), and a driver hospitalized after a highway crash away from any work zone (recorded, but not reportable under the public street exception).
Checklist
- Decide reportability first for urgent events.
- Report within 8 or 24 hours if required.
- Then finish the recordability analysis.
- Record within 7 days.
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
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.
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.
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.39: Reporting fatalities, hospitalizations, amputations, and losses of an eyeOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]29 CFR 1904.7: General recording criteriaOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]29 CFR 1904.29: OSHA Forms 300, 300A, and 301Occupational 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.