Workplace Injury Reporting for Employers: Every Clock, Form and Record

A 2:40 p.m. call from the loading dock

At 2:40 p.m. on a Thursday, a shift supervisor at a distribution center calls the site's operations manager. A forklift has pinned a picker's foot against a rack. An ambulance has taken the picker to the hospital, and nobody yet knows whether the hospital will admit the picker or send them home.

The operations manager reports to a regional director in another state, and the company runs a second site across a state line. Several decisions now hang on facts nobody has. If the hospital admits the picker as an in-patient, a federal clock is already running. If the picker misses work, a state clock may start, with a different trigger and a different recipient. Whether the case belongs on the OSHA 300 Log is a separate decision, and it has its own clock.

The manager has a spreadsheet of dates but not the rule behind each date. That gap, between a date and the rule that produced it, is what this guide tries to close. By the end, you should be able to name each deadline an injury can start, its trigger, unit, recipient and source, and see where the rule ends and your own decision begins.

Reference material with citations, not legal advice. You decide recordability and compensability, and you file.

Workplace injury reporting requirements for employers: the federal OSHA clocks

Start with the idea that organizes everything else: every clock begins on a date the employer knew something. We call that date Day Zero. It is not always the date of the injury. A hospitalization the employer learns about the next morning starts its clock the next morning, and a state clock may start on a different date again. Write down what was known, when, and by whom, because every deadline below is counted from a date like that.

Reporting severe injuries to OSHA

Under 29 CFR 1904.39, an employer must report a work-related fatality to OSHA within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours (OSHA, "Report a fatality or severe injury," checked 2026). If you do not learn of the event when it happens, the 8 or 24 hours run from when it "is reported to you or to any of your agent(s)." If you do not learn right away that it resulted from a work-related incident, they run from when you or your agent learn that it did (29 CFR 1904.39(b)(7)–(8), eCFR, checked 2026).

"An in-patient hospitalization, amputation, or eye loss must be reported within 24 hours." — OSHA, Report a Fatality or Severe Injury (checked 2026)

Two details trip people up. First, a fatality must be reported only if it occurs within 30 days of the work-related incident, and an in-patient hospitalization, amputation or eye loss only if it occurs within 24 hours of the incident (29 CFR 1904.39(b)(6), eCFR, checked 2026; see also OSHA's 2016 enforcement memo). Either way, the case must still be recorded if you keep records. So the report window and the occurrence window are different things, and a case can fall outside one without leaving the other.

Second, the duty applies even to employers that are exempt from routine recordkeeping. A company with 10 or fewer employees at all times during the last calendar year is partially exempt under 29 CFR 1904.1, but it must still report severe injuries and fatalities under 1904.39 (29 CFR 1904.1(a)(1) on eCFR, checked 2026). The 8-hour and 24-hour limits are unchanged for those employers (Texas Department of Insurance summary of the OSHA rule, checked 2026).

How do you report? You can call the nearest OSHA office, call the 24-hour hotline at 1-800-321-6742, or report online (OSHA, checked 2026). The employer makes that report. A tool can remind you which channel applies, but it cannot file for you. For a deeper walk through the criteria and edge cases, see our guide to OSHA severe injury reporting requirements.

The scale is worth a sentence. Employers reported an average of 27 severe injuries and illnesses per day to OSHA in 2022–2023 (OSHA severe injury report, 2022–2023). Those are federal OSHA jurisdiction figures. A report that starts as an ordinary phone call from a supervisor is, for many employers, a routine event, not a rare one.

State Plan states run their own severe-injury clocks

OSHA recognizes 22 State Plans covering both private-sector and state and local government workers, and seven covering public-sector workers only (OSHA State Plans, checked 2026). In a State Plan state, the state agency sets the severe-injury reporting rules for private employers, so check each state's own rule. We cover only three here, and you should check the State Plan list for any other state where you operate.

• California. A serious injury or illness, or a death, must be reported immediately. Cal/OSHA defines "immediately" as no longer than 8 hours after the employer knows, or with diligent inquiry would have known, and the report goes to Cal/OSHA (Title 8 §342, checked 2026). Cal/OSHA assesses a minimum penalty of $5,000 for failing to report a serious injury, illness or death as §342(a) requires (California Labor Code §6409.1(b) sets the same floor; Title 8 §336, checked 2026). The current definition of "serious injury" and the exigent-circumstances window have been amended, so confirm both with Cal/OSHA.
• Michigan. MIOSHA requires employers to report the in-patient hospitalization of one or more employees within 24 hours, replacing the earlier 8-hour rule for hospitalization of three or more employees (MIOSHA instruction ADM-15-6, checked 2026).
• North Carolina. The state's OSH Division requires notice to NCDOL within 8 hours of a work-related fatality, and within 24 hours of an in-patient hospitalization, amputation or loss of an eye (NCDOL, checked 2026).

Recording the case once it is recordable

Reporting a severe injury to OSHA and recording a case on the OSHA 300 Log are different duties. 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 (29 CFR 1904.29(b)(3) on eCFR, checked 2026). The clock runs from information that a recordable case occurred. Recordability itself is your decision, so the seven days start only once you have what you need to make it.

For the difference between the three forms and how each feeds the next, see OSHA 300 vs 300A vs 301.

State first-report deadlines, side by side

Federal OSHA is only one recipient. Many states also require a first report of injury to the carrier, claims administrator or the state agency. The workers' compensation first report often goes to the carrier, with exceptions: Ohio's state fund, Texas non-subscribers, and New York, where the Board does not require the C-2F if the insurer files electronically (form C-2F, New York WCB, checked 2026). A longer treatment of each state sits in first report of injury deadlines by state.

The table below gives the trigger, limit, recipient and source for each of the ten U.S. states we track. The units are those the sources use, and where a source does not define the unit, we say so.

State	Trigger	Limit and unit	Recipient	Source
California (DWC-1)	Notice or knowledge of an injury causing lost time beyond the employee's work shift or medical treatment beyond first aid	1 working day	Employee (provide the claim form)	Labor Code §5401, 2025 code
California (Form 5020)	Employer obtains knowledge of the injury or illness	5 days; calendar or working not stated	Insurer, if insured; the Division directly, if self-insured	8 CCR §14001(d)–(e); Labor Code §6409.1, 2025
Texas	Absence of more than one day, or notice of occupational disease (see conflict below)	"Not later than the eighth day"; how days are counted not stated	Insurance carrier	Tex. Lab. Code §409.005; 28 TAC §120.2, checked 2026
Florida	Actual knowledge of injury or death	7 days; calendar or working not stated	Carrier	Fla. Stat. §440.185(2), checked 2026
New York	Lost time beyond the day or shift, or treatment beyond first aid (see conflict below)	"Immediately" (Board guidance); 10 days (C-2F wording; calendar or working not stated)	Insurer (Board guidance, immediate notice); C-2F recipient not stated in the quoted wording, confirm with the Board	WCB timely reporting guidance; form C-2F, checked 2026
Pennsylvania	Death; or other injury causing disability for the entire day, shift or turn in which it was received, or longer	48 hours (death); 7 days after disability begins (other; calendar or working not stated)	Bureau of Workers' Compensation	34 Pa. Code §121.5; PA DLI flow of a claim, checked 2026
Illinois	Accidental injury causing loss of more than 3 scheduled work days; or accidental death	Between the 15th and 25th of each month; 2 working days for death	The Commission	820 ILCS 305/6(b), checked 2026
Ohio	Injury or occupational disease causing 7 days or more of total disability	Within a week after acquiring knowledge; confirm with Ohio BWC	Bureau of Workers' Compensation	R.C. §4123.28, checked 2026
North Carolina	Absence from work for more than one day, or medical charges above the Commission's amount	5 days after knowledge; calendar or working not stated	Industrial Commission	G.S. 97-92, checked 2026
Georgia	Injury requiring medical or surgical treatment, or causing absence from work for more than seven days	10 days after notice (statute); Board Rule 61 gives insurers 21 days, so plan to the earlier date and confirm with the Board	State Board of Workers' Compensation (WC-1)	O.C.G.A. §34-9-12(a), checked 2026; SBWC 2026 Rules, Rule 61
Michigan	Disability exceeding 7 consecutive days, a death, or a specific loss	"Immediately" per WDCA publication; see source	Workers' Disability Compensation Agency and the carrier (Form WC-100)	Michigan WDCA, checked 2026

A few notes on reading it. Ohio is one of four monopolistic states where coverage must come from a state fund, with North Dakota, Washington and Wyoming (The Hartford, checked 2026). In Ohio, then, the Bureau is both the fund and the recipient. Florida adds an administrative fine of up to $500 for each failure to send a required form, report or notice on time, which applies to the employer when it misses the 7-day notice to the carrier (Fla. Stat. §440.185, 2025). For Georgia, the Board's rules also say employers "shall complete Section A immediately upon knowledge of an injury and submit the form to their insurer" (SBWC 2025 Rules). "Immediately" has no fixed period in that text, so confirm the timing with the Georgia State Board of Workers' Compensation. Where the table says a period is not stated as calendar or working days, ask the named agency how to count it.

Where the sources disagree

Some of these deadlines have two published versions. We show both and attribute each, because a deadline you cannot trace is a deadline you cannot defend.

Texas. The Labor Code requires the report to the carrier "not later than the eighth day after" the employee's absence from work for more than one day due to an injury, or the day the employer receives notice of an occupational disease (Tex. Lab. Code §409.005(b); see also 28 TAC §120.2, checked 2026). The text does not say how the days are counted, so confirm that with Texas DWC. The instructions on Texas DWC Form-001 (Rev. 10/05) describe the trigger as "the employee's first day of absence" and warn that an employer who fails to file without good cause may face an administrative penalty (DWC Form-001 instructions). Those are different triggers. We do not resolve them; confirm with Texas DWC.

Texas non-subscribers have a separate duty. An employer without coverage must report to DWC no later than the seventh day of the month after the month in which a death occurred, an employee was off work more than one day because of an on-the-job injury, or the employer learned of a work-related illness (TDI employer FAQ, checked 2026). Texas is the sole state that lets private-sector employers choose not to buy workers' compensation coverage (TDI/DWC biennial report, 2022), so a mixed multi-state employer may have both a subscriber and a non-subscriber question. TDI names the form as DWC Form-007, Non-covered Employer's Report of Occupational Injury or Illness (TDI employer FAQ). The filing channel is not covered here; confirm it with DWC.

New York. Form C-2F states that a work-related injury or illness must be reported within 10 days under Section 110 or be subject to a penalty (form C-2F, checked 2026). The Board's timely-reporting guidance tells the employer to notify the insurer immediately when an injury causes lost time beyond the working day or shift, or needs treatment beyond ordinary first aid or more than two first-aid treatments. The insurer must then report to the Board by the 18th day after the injury, or within 10 days after the employer learns of it, whichever is greater (WCB guidance, checked 2026). Keep the employer's duty and the insurer's duty separate when you read these. The quoted C-2F wording does not say who receives the form, so confirm that with the Board.

North Carolina. Current Industrial Commission rules (11 NCAC 23A) call for Form 19 when the injury causes absence of more than one day, or medical compensation charges above $4,000 (NC Administrative Code, checked 2026). Confirm the current threshold with the Commission.

Pennsylvania. The regulation gives 48 hours for a death and "7 days after the date disability begins" for other covered injuries (34 Pa. Code §121.5(a)). The DLI summary words the trigger a little differently. Neither says calendar or working days, so confirm the count with the Bureau before you build it into a calendar.

Ontario: Form 7 and the OHSA notices

Ontario is where many U.S. employers first meet a different framework. Three duties run in parallel, and each has a different recipient. All dollar figures in this section are in Canadian dollars (CAD).

WSIB Form 7. WSIB says an employer must file Form 7 within 3 business days (WSIB Form 7 FAQ, checked 2026). Ontario's government guidance describes the same duty as within three days of learning about the injury, and it frames the trigger as a work-related injury where the worker needs health care and also loses time, earns less, or needs modified work at regular pay for more than seven calendar days (ontario.ca, reporting workplace injuries under the WSIA, checked 2026). So one source says "3 business days" and the other says "three days." WSIB's own policy says it must receive the complete report within three business days after the employer learns of the reporting obligation, and that business days "are Monday to Friday, and do not include statutory holidays" (WSIB Operational Policy 15-01-02, checked 2026). Confirm which statutory holidays apply with WSIB. WSIB charges a $250 CAD late-reporting penalty for injuries or illnesses reported after three business days, and $1,000 CAD for those reported more than 30 calendar days late (WSIB Form 7 reference guide, checked 2026). For the details, see WSIB Form 7.

OHSA s.52, written notice. When a person is injured at an Ontario workplace and cannot do their usual work, the employer must give written notice within four days of the incident to the joint health and safety committee or health and safety representative, and to the union if there is one (ontario.ca, reporting workplace incidents and illnesses, checked 2026). This notice does not go to WSIB. It is separate paperwork from Form 7.

OHSA s.51, critical injury or fatality. If a person is critically injured or killed at the workplace, the employer must immediately notify a Ministry of Labour inspector by telephone or other direct means, along with the joint committee or health and safety representative and the union, and send a written report to a Director of the Ministry within 48 hours (ontario.ca guide to the OHSA, Part VII, checked 2026). "Immediately" has no fixed period, and the guide is a summary, so read s.51 of the Act and confirm with the Ministry.

Occupational illness. The notice timing under the OHSA's occupational-illness notice provisions is not covered in this guide. Confirm it with the Ministry of Labour. The Act sets fines, and for individuals possible imprisonment, for offences under it; the current maximums are in Part IX of Ontario's guide to the Act (ontario.ca OHSA guide, Part IX).

What the rule says, and what you decide

Everything above is a deadline. The harder questions are not deadlines. They are judgments about a particular case, and the regulations put those judgments on the employer. In each of the passages below, the rule comes first with its citation, then the decision.

Recordability

The rule: 29 CFR 1904.7 sets the general recording criteria. A case may be recordable when a work-related injury or illness results in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness, among other results (29 CFR 1904.7, eCFR, checked 2026). The line between first aid and medical treatment turns on the first-aid list in 1904.7(b)(5)(ii), and 1904.7(b)(5)(iii) says it is "a complete list of all treatments considered first aid." Read the list itself before deciding.

You may cap the count of days away or days of restriction at 180 calendar days on the log, and a case that starts in one year and causes days away in the next is recorded only once, in the year it occurred (1904.7, OSHA, checked 2026). Days away are counted starting "on the day after the injury occurred," and you count calendar days "regardless of whether or not the employee was scheduled to work" (29 CFR 1904.7(b)(3)(i), (iv)).

The decision: whether this injury is work-related, whether the treatment was medical treatment or first aid, and whether the restriction counts, are yours. A tool can put the rule text in front of the person deciding. It cannot decide for you.

Privacy cases

The rule: 1904.29(b) sets out a complete list of privacy concern cases for which the employee's name is left off the 300 Log (29 CFR 1904.29, eCFR, checked 2026). The list is exclusive, so a case that is not on it does not become a privacy case because it feels sensitive. The decision, again, is yours, and so is the documentation that lets you explain it later.

Which establishment, which employees

The rule: you must keep a separate 300 Log for each establishment expected to operate for one year or longer (29 CFR 1904.30, OSHA, checked 2026). For temporary, leased and contract workers, OSHA applies a day-to-day supervision test: employers record the injuries of workers they supervise on a day-to-day basis, including workers not on their payroll (OSHA interpretation, 2018). Beyond that test, how a host employer and a staffing agency divide the duty is not covered here, so confirm the allocation with OSHA.

The decision: which site a case belongs to, and who supervises a temporary worker day to day, are facts only you can establish.

Compensability

Compensability is a state-law question, answered through the carrier or the state agency. It is not an OSHA question, and recordability does not settle it. ClaimsIntake decides neither, and a first report to a carrier is a notice, not a finding. Treat the two as separate files with separate owners, even if one person holds both.

Keeping the record defensible: the annual cycle, ITA, retention and access

The first report starts the clocks. The record is what you can show later. Most of the annual obligations follow from the 300 Log you build case by case.

The 300A in February

The 300A summary must be posted no later than February 1 of the year following the year the records cover, and kept posted until April 30 (NCDOL, reproducing 29 CFR 1904.32, February 2026). A company executive must certify it. That executive must be one of four people:

• an owner, for a sole proprietorship or partnership only;
• an officer of the corporation;
• the highest-ranking company official working at the establishment;
• that official's immediate supervisor.

The source is 29 CFR 1904.32 on eCFR (checked 2026). For a multi-site employer, a practical question is who each establishment's certifier is, and whether that person has the log in front of them on January 28. Write it down before January.

Electronic submission by March 2

Covered establishments must submit data electronically through OSHA's Injury Tracking Application (ITA) by March 2 of the year after the covered year. Calendar-year 2025 data was due March 2, 2026 (OSHA ITA user guide, checked 2026).

Under 29 CFR 1904.41, establishments with 20–249 employees in designated higher-hazard industries (Subpart E, Appendix A) must submit 300A data electronically. Establishments with 100 or more employees in Appendix B industries must also submit 300 and 301 data (OSHA interpretation, 2024-04-16). That second requirement began in 2024 for the 2023 reporting period (OSHA 2023 injury and illness summary). OSHA also publishes establishment-specific data for establishments with 250 or more employees in non-exempt industries (OSHA ITA data, checked 2026). The industry lists are not reproduced here, so check yours against 29 CFR 1904.41 and the appendices to Subpart E.

Why should an operations manager care about the ITA before an inspection? OSHA tells compliance officers to check the ITA database during all inspections to identify employers that were required to submit records but did not (OSHA interpretation, 2024). A March 2026 OSHA memo sets up a program in which area offices match open inspections against establishments that may not have submitted calendar-year 2025 Form 300A data (OSHA memo, 2026-03-23). The scale of the data is large: for calendar year 2023, OSHA received 300A data on more than 1.5 million work-related injuries and illnesses from more than 385,000 establishments (OSHA, 2023 data).

The ITA is OSHA's authoritative channel, and the employer submits through it. OSHA's injury reporting page explains the process. A workbook or app can prepare the figures you will enter. It does not submit them.

Retention

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), eCFR, checked 2026). The employer carries that duty. Any software you use has its own retention terms, and those are not a substitute for yours. Export what you need and store it on your own schedule.

Access

Access requests come with short clocks. When an employee, former employee or employee representative asks for a copy of the 300 Log, you must provide it by the end of the next business day, and the first copy is free (29 CFR 1904.35, eCFR, checked 2026). When an authorized government representative asks for Part 1904 records, you must provide copies within four business hours (29 CFR 1904.40, eCFR, checked 2026). Four business hours is not enough time to start looking for the log.

The case for a trail

An audit trail records what was known, when, and under which version of the rule. That is useful for a few reasons beyond OSHA: a state agency may ask why a report was filed on a given day, an insurer may ask for the log, and a new owner of the process needs to understand the old one. Rules also change, so a date that was right under last year's rule may be wrong under this year's. A date without a citation and a verification date is hard to defend.

For context on volume, BLS reported that private-industry employers recorded 2.5 million nonfatal workplace injuries and illnesses in 2024, down 3.1 percent from 2023, with a total recordable case rate of 2.3 per 100 full-time-equivalent workers (BLS SOII, 2024 data, released January 2026). Those are national totals. Your own count is what the log must hold.

Where tools fit, and what to set up first

Most employers we describe in this guide run injury reporting on email threads, calendar reminders, and Excel or Google Sheets, then hand-fill the blank OSHA forms. That works, and many teams built theirs carefully. A spreadsheet holds dates well. What it does not hold is the rule that produced each date, or a record of which version of the rule was in force when the clock started.

The other options sit in different categories, and most of them are complementary.

• Carrier and state portals. They are free and authoritative, one carrier or state at a time. You will file through them regardless.
• Nurse-triage services. They handle clinical triage and often the first report to the carrier. The employer's compliance record and clock management sit alongside that work.
• EHS suites. They are priced and scoped as a suite for safety departments, and they go well beyond injury reporting.
• Generic incident-reporting apps. They are typically priced per seat and built around forms.
• Chat answers. A chat answer with no citation or verification date is not a defensible deadline.

ClaimsIntake, published by Rovaryn Digital Inc., is reference and workflow software built around those gaps. Rovaryn is a software publisher, not a law firm, insurer, TPA or safety consultancy, and it is not affiliated with or endorsed by OSHA, any State Plan, any state workers' compensation agency or WSIB. We read the cited regulation and agency text and built the rule logic and workbooks from it.

For employers with 20–100 employees in one state, the store workbooks are the right starting point. The workbooks compute deadline dates, recordability logic, days-away and restricted counts, a log that rolls into the 300A, multi-site consolidation, incidence rates, and lag and timeliness checks. Browse them in the store. The subscription app is not live. It is being built as one injury report that will show every deadline that applies, the source of each, and an OSHA record that builds itself from the same report. Each rule row will carry its agency citation and a "last verified" date. Each row will show whether it has been verified against the agency text, and we will not call a rule verified until it has been. The app's features, in the future tense, will include a knowledge-date clock engine, escalating email alerts to an owner and a backup contact, and a pre-filled OSHA 301. The employer will still decide recordability, compensability and what to file, and ClaimsIntake will not submit anything to anyone.

What to set up this month

You can do the following without buying anything.

1. Name an owner and a backup for injury reporting at each site, and write both down.
2. List your jurisdictions. For each state or province where you have employees, find the first-report rule and its recipient, and copy the citation next to it.
3. Mark the conflicts. For Texas, New York, North Carolina, Pennsylvania and Ontario, record both versions of the rule and the agency you will confirm with.
4. Set the annual dates. February 1, March 2 and April 30 belong on the calendar of each site's certifier.
5. Decide how you will record Day Zero: who writes down when the employer learned of the event, and where.
6. Confirm retention. Put the five-year record rule on your own schedule, regardless of what software you use.

For a first-hour checklist after an injury, see what to do when an employee gets hurt at work.

Reference material with citations, not legal advice. You decide recordability and compensability, and you file.

If you want to follow what we are building, join the waitlist. We will write to you about new guides and when the app is ready, and we will not promise a date before there is one.