A Thursday call: recordable, reportable, or both?
At 4:50 p.m. on a Thursday, an HR manager at a three-site parts manufacturer gets a text from a plant supervisor. A machine operator has been driven to an urgent care clinic with a deep hand laceration. The clinic closed it with stitches and sent him home.
Two questions arrive at once. The plant manager asks whether this goes on the OSHA 300 log. The newly appointed safety coordinator asks whether someone has to call OSHA tonight. Both questions are fair, and they are not the same question.
Each comes from a different section of 29 CFR Part 1904, with its own trigger, clock and recipient. Mixing them up leads to over-reporting in some cases and a missed clock in others. By the end of this article you will be able to tell which duty an event triggers, name each clock, and see where the decision is yours.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
OSHA recordable vs reportable: the two duties side by side
Recording and reporting answer different questions. Recording is a bookkeeping duty that decides what goes on your OSHA 300 Log and 301 Incident Report. Reporting is a notification duty that tells OSHA about a narrow set of severe events, quickly. The table shows the difference.
| Duty | Trigger | Unit and limit | Recipient | Source |
|---|---|---|---|---|
| Report a fatality | A work-related fatality; reportable if the death occurs within 30 days of the work-related incident | Hours: within 8 hours | OSHA | 29 CFR 1904.39(a)(1), (b)(6); OSHA reporting page (checked 2026); OSHA memo (2016) |
| Report an in-patient hospitalization, amputation or eye loss | A work-related incident; reportable if the event occurs within 24 hours of the incident | Hours: within 24 hours | OSHA | 29 CFR 1904.39(a)(2), (b)(6); OSHA reporting page (checked 2026); OSHA memo (2016) |
| Record a case | Receiving information that a recordable injury or illness has occurred | Calendar days: within seven calendar days | Your OSHA 300 Log and 301 Incident Report (your own records) | 29 CFR 1904.29(b)(3) (checked 2026) |
The third row has no outside recipient. The log and the 301 are your own records, not a notification to OSHA. The first two rows are the opposite: they go to OSHA, on a clock measured in hours.
Back to the Thursday call. On the facts as described, a laceration closed with stitches is not a fatality, an in-patient hospitalization, an amputation or an eye loss, so the reporting clocks do not start. Whether the case belongs on the log is a separate question under 1904.7, and the answer is yours.
Reportable events under 1904.39: the clocks and the channels
Under 29 CFR 1904.39(a), an employer must report a work-related fatality to OSHA within 8 hours, as OSHA's reporting page also states (checked 2026). A work-related in-patient hospitalization, amputation or eye loss must be reported to OSHA within 24 hours under the same section. If you learn of the event, or that it was work-related, only later, the hours run from when you or your agent learn of it (1904.39(b)(7)–(8)).
"An in-patient hospitalization, amputation, or eye loss must be reported within 24 hours." — OSHA, Report a Fatality or Severe Injury (checked 2026)
The rule adds the windows. A fatality is reportable to OSHA if it occurs within 30 days of the work-related incident. An in-patient hospitalization, amputation or eye loss is reportable if it occurs within 24 hours of the incident (1904.39(b)(6); see also the OSHA memo, 2016). Those windows are why a death that follows an injury by a few weeks can still start an 8-hour clock.
You can reach OSHA three ways: call the nearest OSHA office, call the 24-hour hotline at 1-800-321-6742, or report online. Anyone searching for the OSHA serious event reporting online form is looking for the online option on that same reporting page. ClaimsIntake never submits to OSHA. The employer does.
The term "in-patient hospitalization" matters here. OSHA defines it as "a formal admission to the in-patient service of a hospital or clinic for care or treatment," and an admission "that involves only observation or diagnostic testing" is not reportable (1904.39(b)(9)–(10)). Read the definition itself when a case is borderline. The 24-hour hospitalization guide works through those cases, and the severe injury reporting overview covers the full rule.
Size does not remove the duty. A company with 10 or fewer employees at all times during the last calendar year qualifies for the partial exemption from routine recordkeeping in 29 CFR 1904.1 (checked 2026). The same paragraph says that all employers covered by the OSH Act must still report to OSHA a work-related fatality, in-patient hospitalization, amputation or loss of an eye, as 1904.39 requires (1904.1(a)(1)).
For scale, employers reported an average of 27 severe injuries and illnesses to OSHA per day in 2022–2023 (OSHA severe injury report).
Recordable cases under 1904.7 and 1904.29: what you decide
Recording is a judgment about a specific case, made against a specific rule. Section 1904.7(a) sets the general recording criteria (checked 2026): an 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." Under 1904.7(b)(7), certain significant cases diagnosed by a physician or other licensed health care professional, such as a fractured or cracked bone, must also be recorded. The case must also be work-related under 29 CFR 1904.5 and a new case, because 1904.4(a) requires all three before a case is recorded.
That is what the rule says. The employer decides whether a given case meets it. Whether treatment counts as medical treatment or first aid is the most common sticking point, and the recordable vs first aid guide covers it.
Several details of 1904.7 and 1904.29 are worth knowing:
- The record clock. Under 29 CFR 1904.29, each recordable injury or illness must be entered on the 300 Log and the 301 Incident Report within seven calendar days of receiving information that a recordable case has occurred (1904.29(b)(3), eCFR, checked 2026). The clock starts from information about a recordable case, and you decide whether the case is recordable.
- The day cap. You may cap the count of days away or days of restriction at 180 calendar days (29 CFR 1904.7, checked 2026).
- One entry only. A case that starts in one year and causes days away in the next is recorded once, in the year it occurred (1904.7(b)(3)(ix), checked 2026).
- Privacy cases. Section 1904.29(b) gives a complete list of privacy concern cases, for which the employee's name is left off the log (29 CFR 1904.29, checked 2026). No other case qualifies for that treatment.
The recordable injury guide walks through the full decision sequence.
Where the two duties overlap, and where State Plans differ
A reportable event is not automatically a closed question for the log. If a fatality, hospitalization, amputation or eye loss is work-related, the case still has to be evaluated for recording under 1904.7. The reverse also holds: a log entry does not satisfy a reporting duty, and a call to OSHA does not create a log entry. Each duty needs its own decision and its own record.
The clocks also run differently. The reporting clocks are measured in hours from the event, or from when you learn of it. The recording clock is measured in calendar days from information that a recordable case occurred. That information date, the date you knew, is a useful Day Zero for the file, and writing it down helps with both duties.
State Plans add a layer. Federal OSHA lists 22 State Plans covering both private sector and state and local government workers, and seven covering public-sector workers only (checked 2026). Anyone searching for an OSHA State Plan states list should start at that page. Three examples show the pattern:
- California. Under Cal/OSHA's Title 8 §342, an employer must report a serious injury or illness or a death to Cal/OSHA immediately, meaning no longer than 8 hours after the employer knows, or with diligent inquiry would have known (checked 2026). If the employer can show exigent circumstances, the section allows up to 24 hours after the incident. Cal/OSHA defines "serious injury or illness" separately, so confirm the definition with Cal/OSHA before relying on it.
- Michigan. MIOSHA requires employers to report the in-patient hospitalization of one or more employees to MIOSHA within 24 hours (MIOSHA-ADM-15-6, checked 2026).
- North Carolina. NCDOL's OSH Division requires notice to NCDOL within eight hours of a work-related fatality, and within 24 hours of an in-patient hospitalization, amputation or loss of an eye (NCDOL, checked 2026).
For sites in other State Plan states, confirm the trigger, unit and recipient with that state's agency. Do not assume the federal wording applies.
Keeping both duties defensible
Most failures here are not a misreading of the rule. They come from a missing record: the date the event became known, who decided recordability, and which version of the rule was in front of them. A spreadsheet holds the dates but not the rule that produced them, and email threads scatter the decision.
A workable file for each event captures the knowledge date, the reporting decision with the channel used, and the recordability decision with its citation. It also notes who made each call. Retention is your responsibility. OSHA 300 Logs, 300A summaries and 301 Incident Reports must be kept for five years following the end of the calendar year the records cover (29 CFR 1904.33(a), checked 2026).
Tools fit around that file, not instead of it. Spreadsheets with email are flexible and familiar. OSHA's own channels, and your carrier's or state's, are free and authoritative, one at a time. ClaimsIntake's app is being built to sit between them. It will show the clocks an event starts, with a citation and a "last verified" date on each rule row, and it will link to the OSHA or State Plan reporting channel when a severe-injury prompt applies. It will never report, record or decide for you. The app is not live yet, and the waitlist is the way to follow it. A single-state employer with 20–100 employees may find the store workbooks a better fit.
Your next step is practical. Write down, for each site, who calls OSHA or the State Plan agency after hours, and who is their backup. Then confirm the State Plan agency and timing for any site in California, Michigan, North Carolina or another State Plan state. Finally, check your last three cases to see whether the reporting decision and the recording decision were each documented separately.
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