Why OSHA Injury and Illness Records Exist

The purpose of 29 CFR Part 1904, what a recorded case does and does not mean, and how this course is positioned.

12 min

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Every year, many employers in the United States must keep a record of the work-related injuries and illnesses that happen to their employees. The rule that requires this is 29 CFR Part 1904, "Recording and Reporting Occupational Injuries and Illnesses". CFR means the Code of Federal Regulations. The Occupational Safety and Health Administration (OSHA) enforces it.

The records have three main uses:

  • For the employer: they show where people are getting hurt, so that hazards can be found and controlled.
  • For employees: they show workers what injuries and illnesses happen where they work. Employees have a right to see them.
  • For the government: OSHA uses the data to decide where to inspect and where to offer help, and the Bureau of Labor Statistics (BLS) uses it to build national injury and illness statistics.

A recorded case is not an admission of fault

Many people resist recording a case because they think it means the company did something wrong. It does not. Part 1904 says plainly that recording or reporting a work-related injury or illness does not mean that the employer or the employee was at fault, that an OSHA rule was broken, or that the employee is eligible for workers’ compensation or other benefits.

This matters in practice. Recordability and workers’ compensation are two separate systems with separate rules. A case can be recordable under OSHA and denied under the state workers’ compensation system, and the other way round. Never decide one by looking at the other.

Three systems people confuse

Federal rule (29 CFR Part 1904). Decides what goes on the OSHA 300 Log, 301 incident report and 300A summary. Uses its own definitions of work-related, medical treatment and first aid.

An example

At a Quorvale Logistics warehouse in Texas, a picker strains her shoulder lifting a carton. The clinic gives her a prescription-strength anti-inflammatory. The site manager says, "She was lifting wrongly, so it was her fault — we should not log it." That reasoning is wrong twice. First, fault has nothing to do with recordability. Second, prescription medication is medical treatment beyond first aid, which makes the case recordable if it is work-related and new. You will learn each of these tests in the modules that follow.

A supervisor says, "If we record this injury, we are admitting we broke an OSHA rule." What is the correct reply?

Who uses the records, and for what?

Match each user to its main use of the injury and illness records.

  • The employer
  • Employees and their representatives
  • OSHA
  • The Bureau of Labor Statistics
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