OSHA Recordkeeping

Upon completing this program, participants will be able to:

• Determine which employers must maintain OSHA injury and illness records: the 10-employee threshold, partially exempt industries, state-plan variations, and the reporting obligations that apply even to exempt employers.
• Apply the general recording criteria (§1904.7): an injury or illness is recordable if it is work-related, is a new case, and meets one or more recording criteria — death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a physician.
• Determine work-relatedness (§1904.5): applying the geographic and temporal presumption (injury on employer premises during work is presumed work-related), the specific exceptions (eating, self-inflicted, personal tasks, voluntary wellness, parking lot, common cold/flu, mental illness from non-work), and the grey-area cases that generate the most recordkeeping errors.
• Distinguish first aid from medical treatment: the specific first aid treatments listed in §1904.7(a) (wound cleaning, bandages, non-prescription medications, hot/cold therapy, finger splints, eye patches, etc.) versus medical treatment (prescription medications, sutures, physical therapy, surgical procedures) that trigger recordability.
• Complete the OSHA 300 Log correctly: case number, employee name (or privacy case number), job title, date, where the event occurred, injury description, classification (death, days away, restricted/transfer, other recordable), days counted, and the column-by-column accuracy that withstands OSHA audit.
• Complete the OSHA 300A Annual Summary: calculating annual totals, the certification requirement (company executive must certify), the posting period (February 1 through April 30), and the establishment-level reporting that multi-location employers must maintain.
• Complete the OSHA 301 Incident Report for each recordable case: the detailed case information that supplements the 300 Log entry, or acceptable substitute forms (workers’ compensation first report of injury if it contains equivalent information).
• Report severe injuries under §1904.39: fatalities within 8 hours, in-patient hospitalisations, amputations, and losses of an eye within 24 hours — the reporting triggers, reporting methods (phone or online), and the information OSHA requires.
• Submit electronic recordkeeping data via the OSHA Injury Tracking Application (ITA): which establishments must submit, submission deadlines, data fields, and the electronic compliance requirement that took effect in 2017.
• Calculate TRIR, DART, and severity rates: Total Recordable Incident Rate (recordable cases × 200,000 / hours worked), Days Away Restricted or Transferred rate, severity rate, and how these metrics are used for benchmarking, insurance, and contractor prequalification.

Core Curriculum Topics

• Coverage and Exemptions (§1904.1–2): which employers must keep records, partially exempt industries, state plans
• General Recording Criteria (§1904.7): the three-part test — work-related + new case + meets recording criteria
• Work-Relatedness (§1904.5): geographic presumption, specific exceptions, and grey-area decision-making
• First Aid vs Medical Treatment: the exhaustive first aid list and its application to recordability decisions
• Special Recording Criteria: needlestick/sharps (§1904.8), tuberculosis (§1904.9), hearing loss (§1904.10), musculoskeletal disorders
• Privacy Concern Cases (§1904.29): which cases require privacy protection and how to record them
• OSHA 300 Log: line-by-line completion, column classification, and common errors
• OSHA 300A Annual Summary: calculation, executive certification, posting dates, multi-establishment requirements
• OSHA 301 Incident Report: detailed case information and acceptable substitute forms
• Severe Injury Reporting (§1904.39): 8-hour fatality, 24-hour hospitalisation/amputation/eye loss
• Electronic Submission (ITA): which employers, deadlines, data fields, portal navigation
• TRIR, DART, and Severity Rate Calculation: formulas, hours-worked denominators, benchmarking, and prequalification use
• Record Retention: 5-year requirement, updating for reclassified cases, employee access rights
• Anti-Retaliation (§1904.35(b)(1)(iv)): prohibition against discouraging injury reporting, post-incident drug testing limitations
• Common Recordkeeping Errors: the mistakes that generate citations and how to avoid them

• No prior training required
• Essential for anyone who makes recordability decisions or maintains OSHA records
• No academic degree required
• All instruction in English; working proficiency required

Upon completion, graduates receive an American Institute of Safety Professionals certificate, wallet card, and transcript. Employer-verifiable at amiosp.com/student-verifications.

• Safety officers responsible for maintaining the OSHA 300 Log and making recordability decisions
• HR managers who manage workers’ compensation claims and need to understand the parallel OSHA recording requirements
• Safety managers who oversee recordkeeping compliance, calculate injury rates, and report performance metrics
• Occupational health nurses who determine whether injuries require medical treatment beyond first aid
• Risk managers and insurance coordinators who use TRIR, DART, and EMR for insurance and prequalification
• Supervisors who complete initial incident reports and must understand what information is needed
• Anyone designated to make the record-it or don’t-record-it decision for their organisation

• OSHA Recordkeeping — YOU ARE HERE (29 CFR 1904 specialist course)
• OSHA Worker Rights and Protection (includes record access as one worker right)
• CHSO / RHSO (recordkeeping as one safety officer function)
• CHSM / RHSM (performance metrics and management reporting that use recordkeeping data)