FactSheetUpdates to OSHA’s Recordkeeping Rule: An Overview The Occupational Safety and Health Administration’s updated recordkeeping rule includes two key changes. First, the rule updates the list of industries that are exempt from the requirement to routinely keep OSHA injury and illness records due to relatively low occupational injury and illness rates. The previous list of industries was based on the old Standard Industrial Classification (SIC) system and injury and illness data from the Bureau of Labor Statistics (BLS) from 1996-1998.

The new list of industries that are exempt from routinely keeping OSHA injury and illness records is based on the North American Industry Classification System (NAICS) and injury and illness data from the Bureau of Labor Statistics (BLS) from 2007-2009. Note: The new rule retains the exemption for any establishment with ten or fewer employees, regardless of their industry classification, from the requirement to routinely keep records.

Second, the rule expands the list of severe work-related injuries and illnesses that all covered employers must report to OSHA. The revised rule retains the current requirement to report all fatalities within 8 hours and adds the requirement to report all inpatient hospitalizations, amputations and loss of an eye within 24 hours to OSHA.

The new requirements will take effect on January 1, 2015. Establishments located in states under Federal OSHA jurisdiction must begin to comply with the new requirements on January 1, 2015. Establishments located in states that operate their own safety and health programs should check with their state plan for the implementation date of the new requirements.

The final rule will allow OSHA to focus its efforts more effectively to prevent fatalities and severe work-related injuries and illnesses. The final rule will also improve access by employers, employees, researchers and the public to information about workplace safety and health and increase their ability to identify and abate serious hazards.

Changes to reporting requirements: What needs to be reported to OSHA?OSHA’s updated recordkeeping rule expands the list of severe injuries and illnesses that employers must report to OSHA.

As of January 1, 2015, all employers must report:

• All work-related fatalities within 8 hours.• All work-related inpatient hospitalizations, all

amputations and all losses of an eye within 24 hours.

• You can report to OSHA by: { Calling OSHA’s free and confidential number

at 1-800-321-OSHA (6742) { Calling your closest OSHA Area Office

during normal business hours { Using the new online form that will soon be

available.

Only fatalities occurring within 30 days of the work-related incident must be reported to OSHA. Further, for an inpatient hospitalization, amputation or loss of an eye, these incidents must be reported to OSHA only if they occur within 24 hours of the work-related incident.

Changes to recording requirements: Who is required to keep records?OSHA regulations require certain employers to routinely keep records of serious employee injuries and illnesses. However, there are two classes of employers that are partially

exempt from routinely keeping records. First, employers with ten or fewer employees at all times during the previous calendar year are exempt from routinely keeping OSHA injury and illness records. OSHA’s revised recordkeeping regulation maintains this exemption.

Second, establishments in certain low-hazard industries are also exempt from routinely keeping OSHA injury and illness records. Since 1982, this list has included establishments in the divisions of retail trade; finance, insurance and real estate; and the service industry if the three-year average lost workday case rate for their major industry group was 75 percent less than the overall three-year average of the lost workday case rate for private industry. OSHA’s revised recordkeeping regulation provides an updated list of low‑hazard

industries that are exempt from routinely keeping OSHA injury and illness records. The new list of exempt industries is now classified by the North American Industry Classification System (NAICS), which is the standard used by federal statistical agencies in classifying business establishments for the purpose of collecting, analyzing and publishing statistical data related to the U.S. business economy. The injury and illness rate threshold for an exemption is based on more recent BLS data.

Where can I find more information?For more information about the new reporting requirements and updated industry lists, visit OSHA’s webpage on the updated recordkeeping rule at www.osha.gov/recordkeeping2014.

Table 1: New List of Partially Exempt Industries

NAICS Code and Industry Description

4412 Other Motor Vehicle Dealers

5151 Radio and Television Broadcasting

5412 Accounting, Tax Preparation, Bookkeeping, and Payroll Services

6213 Offices of Other Health Practitioners

4431 Electronics and Appliance Stores

5172 Wireless Telecommunications Carriers (except Satellite)

5413 Architectural, Engineering, and Related Services

6214 Outpatient Care Centers

4461 Health and Personal Care Stores

5173 Telecommunications Resellers

5414 Specialized Design Services

6215 Medical and Diagnostic Laboratories

4471 Gasoline Stations 5179 Other Telecommunications

5415 Computer Systems Design and Related Services

6244 Child Day Care Services

4481 Clothing Stores 5181 Internet Service Providers and Web Search Portals

5416 Management, Scientific, and Technical Consulting Services

7114 Agents and Managers for Artists, Athletes, Entertainers, and Other Public Figures

4482 Shoe Stores 5182 Data Processing, Hosting, and Related Services

5417 Scientific Research and Development Services

7115 Independent Artists, Writers, and Performers

4483 Jewelry, Luggage, and Leather Goods Stores

5191 Other Information Services

5418 Advertising and Related Services

7213 Rooming and Boarding Houses

4511 Sporting Goods, Hobby, and Musical Instrument Stores

5211 Monetary Authorities - Central Bank

5511 Management of Companies and Enterprises

7221 Full-Service Restaurants

NAICS Code and Industry Description

4512 Book, Periodical, and Music Stores

5221 Depository Credit Intermediation

5611 Office Administrative Services

7222 Limited-Service Eating Places

4531 Florists 5222 Nondepository Credit Intermediation

5614 Business Support Services

7224 Drinking Places (Alcoholic Beverages)

4532 Office Supplies, Stationery, and Gift Stores

5223 Activities Related to Credit Intermediation

5615 Travel Arrangement and Reservation Services

8112 Electronic and Precision Equipment Repair and Maintenance

4812 Nonscheduled Air Transportation

5231 Securities and Commodity Contracts Intermediation and Brokerage

5616 Investigation and Security Services

8114 Personal and Household Goods Repair and Maintenance

4861 Pipeline Transportation of Crude Oil

5232 Securities and Commodity Exchanges

6111 Elementary and Secondary Schools

8121 Personal Care Services

4862 Pipeline Transportation of Natural Gas

5239 Other Financial Investment Activities

6112 Junior Colleges 8122 Death Care Services

4869 Other Pipeline Transportation

5241 Insurance Carriers 6113 Colleges, Universities, and Professional Schools

8131 Religious Organizations

4879 Scenic and Sightseeing Transportation, Other

5242 Agencies, Brokerages, and Other Insurance Related Activities

6114 Business Schools and Computer and Management Training

8132 Grantmaking and Giving Services

4885 Freight Transportation Arrangement

5251 Insurance and Employee Benefit Funds

6115 Technical and Trade Schools

8133 Social Advocacy Organizations

5111 Newspaper, Periodical, Book, and Directory Publishers

5259 Other Investment Pools and Funds

6116 Other Schools and Instruction

8134 Civic and Social Organizations

5112 Software Publishers 5312 Offices of Real Estate Agents and Brokers

6117 Educational Support Services

8139 Business, Professional, Labor, Political, and Similar Organizations

5121 Motion Picture and Video Industries

5331 Lessors of Nonfinancial Intangible Assets (except Copyrighted Works)

6211 Offices of Physicians

5122 Sound Recording Industries

5411 Legal Services 6212 Offices of Dentists

DEA FS-3744 09/2014

This is one in a series of informational fact sheets highlighting OSHA programs, policies or standards. It does not impose any new compliance requirements. For a comprehensive list of compliance requirements of OSHA standards or regulations, refer to Title 29 of the Code of Federal Regulations. This information will be made available to sensory‑impaired individuals upon request. The voice phone is (202) 693‑1999; teletypewriter (TTY) number: (877) 889‑5627.

Table 2: Industries That Include Establishments Newly Required to Keep Records

NAICS Code Title of NAICS Code

3118 Bakeries and tortilla manufacturing

4411 Automobile dealers

4413 Automotive parts, accessories, and tire stores

4441 Building material and supplies dealers

4452 Specialty food stores

4453 Beer, wine, and liquor stores

4539 Other miscellaneous store retailers

4543 Direct selling establishments

5311 Lessors of real estate

5313 Activities related to real estate

5322 Consumer goods rental

5324 Commercial and industrial machinery and equipment rental and leasing

5419 Other professional, scientific, and technical services

5612 Facilities support services

5617 Services to buildings and dwellings

5619 Other support services

6219 Other ambulatory health care services

6241 Individual and family services

6242 Community food and housing, and emergency and other relief services

7111 Performing arts companies

7113 Promoters of performing arts, sports, and similar events

7121 Museums, historical sites, and similar institutions

7139 Other amusement and recreation industries

7223 Special food services

8129 Other personal services

FactSheetUpdates to OSHA’s Recordkeeping Rule: Reporting Fatalities and Severe InjuriesOSHA’s updated recordkeeping rule expands the list of severe injuries that all employers must report to OSHA. Establishments located in states under Federal OSHA jurisdiction must begin to comply with the new requirements on January 1, 2015. Establishments located in states that operate their own safety and health programs should check with their state plan for the implementation date of the new requirements.

What am I required to report under the new rule?Previously, employers had to report the following to OSHA:

• All work-related fatalities• Work-related hospitalizations of three or more

employees

Starting in 2015, employers will have to report the following to OSHA:

• All work-related fatalities • All work-related inpatient hospitalizations of

one or more employees• All work-related amputations• All work-related losses of an eye

Who is covered under the new rule?All employers under OSHA jurisdiction must report all work-related fatalities, hospitalizations, amputations and losses of an eye to OSHA, even employers who are exempt from routinely keeping OSHA injury and illness records due to company size or industry.

An amputation is defined as the traumatic loss of a limb or other external body part. Amputations include a part, such as a limb or appendage, that has been severed, cut off, amputated (either completely or partially); fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; and amputations of body parts that have since been reattached.

How soon must I report a fatality or severe injury or illness?Employers must report work-related fatalities within 8 hours of finding out about them.

Employers only have to report fatalities that occurred within 30 days of a work-related incident.

For any inpatient hospitalization, amputation, or eye loss employers must report the incident within 24 hours of learning about it. Employers only have to report an inpatient hospitalization, amputation or loss of an eye that occurs within 24 hours of a work-related incident.

How do I report an event to OSHA?Employers have three options for reporting the event:

• By telephone to the nearest OSHA Area Office during normal business hours.

• By telephone to the 24-hour OSHA hotline at 1-800-321-OSHA (6742).

• OSHA is developing a new means of reporting events electronically, which will be available soon at www.osha.gov.

What information do I need to report?For any fatality that occurs within 30 days of a work-related incident, employers must report the event within 8 hours of finding out about it.

For any inpatient hospitalization, amputation, or eye loss that occurs within 24 hours of a work-related incident, employers must report the event within 24 hours of learning about it.

Employers reporting a fatality, inpatient hospitalization, amputation or loss of an eye to OSHA must report the following information:

• Establishment name• Location of the work-related incident• Time of the work-related incident• Type of reportable event (i.e., fatality, inpatient

hospitalization, amputation or loss of an eye)• Number of employees who suffered the event• Names of the employees who suffered the event• Contact person and his or her phone number• Brief description of the work-related incident

Employers do not have to report an event if it:

• Resulted from a motor vehicle accident on a public street or highway. Employers must report the event if it happened in a construction work zone.

• Occurred on a commercial or public transportation system (airplane, subway, bus, ferry, streetcar, light rail, train).

• Occurred more than 30 days after the work-related incident in the case of a fatality or more than 24 hours after the work-related incident in the case of an inpatient hospitalization, amputation, or loss of an eye.

Employers do not have to report an inpatient hospitalization if it was for diagnostic testing or observation only. An inpatient hospitalization is defined as a formal admission to the inpatient service of a hospital or clinic for care or treatment.

Employers do have to report an inpatient hospitalization due to a heart attack, if the heart attack resulted from a work-related incident.

Where can I find more information?For more information about the updated reporting requirements, visit OSHA’s webpage on the revised recordkeeping rule at www.osha.gov/recordkeeping2014.

DEA FS-3745 09/2014

This is one in a series of informational fact sheets highlighting OSHA programs, policies or standards. It does not impose any new compliance requirements. For a comprehensive list of compliance requirements of OSHA standards or regulations, refer to Title 29 of the Code of Federal Regulations. This information will be made available to sensory-impaired individuals upon request. The voice phone is (202) 693-1999; teletypewriter (TTY) number: (877) 889-5627.

WAS IT

FATAL? NO

NO

NO YES

YES

YES NO

WAS THE

WORKER

ADMITTED

TO A

HOSPITAL?

WAS

THERE AN

AMPUTATION?

DID

SOMEONE

LOSE AN

EYE?

REPORT

TO OSHA

WITHIN

8 HOURS

REPORT

TO OSHA

WITHIN

24 HOURS

NO REPORT

REQUIRED

NEW NEW NEW REPORTING REPORTING REPORTING

EXPLAINEDEXPLAINEDEXPLAINED ‘s WORKER IS INJUREDWORKER IS INJURED

HOW DO I REPORT?

1. Call 1-800-321-OSHA (6742) or

2. Call your local OSHA office:

Appleton (920) 734-4521

Eau Claire (715)832-9019

Madison (608) 441-5388

Milwaukee (414) 297-3315

Visit OSHA’s recordkeeping and reporting page for

more information and updates:

http://www.osha.gov/recordkeeping2014/index.html

Step 1

9

Step 2

OSHA 7‐Step Injury and Illness Recordkeeping Decision Process

Step 3

Step 4

Did the employee experience an injury or illness?

Is the injury or illness work‐

related?

Do any of the 

exceptions apply to the 

case?

Exceptions to Work Relatedness [1904.5(b)(2)]1. Present as member of general public2. Symptoms surface at work, but solely non‐work‐related3. Voluntary participation in medical, fitness event4. Personal consumption5. Personal tasks outside of working hours6. Personal grooming or intentionally self‐inflicted7. Motor vehicle during commute8. Common cold or flu9. Mental illness

Determination of Work‐Relatedness [1904.5] Work‐relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment unless an exception specifically applies.

A case is presumed work‐related if, and only if, an event or exposure in the work environment is a discernable cause of the injury or illness or of a significant aggravation to a pre‐existing condition.

Was an employee involved?

Basic Requirements [1904.31]Record injuries and illnesses of all employees on your payroll, whether they are labor, executive, hourly, salary, part‐time, seasonal, or migrant workers. Also includes those not on your payroll if you supervise them on a day‐to‐day basis.

Definition [1904.46]An injury or illness is an abnormal condition or disorder. Injuries include cases such as, but not limited to, a cut, fracture, sprain, or amputation. Illnesses include both acute and chronic illnesses, such as, but not limited to, a skin disease, respiratory disorder, or poisoning.

YES

YES

YES

NO

YES                           Stop! Case is not recordable!

Step 5

10

Is the injury or illness a new case?

Step 6

Step 7

Does the 

recording? 

Does the case meet any of the criteria for recording? 

Record the injury or illness

Determination of a new case [1904.6]Consider an injury or illness a “new case” if the employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body, OR

the employee previously experienced a recorded injury or illness of the same type that affected the same part of body but had recovered completely (all signs and symptoms had disappeared) from the previous injury or illness and an event or exposure in the work environment caused the signs or symptoms to reappear.

General Recording Criteria [1904.7]An injury or illness is recordable if it resultsin one or more of the following:• Death• Days away from work• Restricted work activity• Transfer to another job• Medical treatment beyond first aid• Loss of consciousness• Significant injury or illness diagnosedby a PLHCP

Specific Cases[1904.8 – 1904.11]• Needlesticks & Sharps• Medical removal• Hearing loss• Tuberculosis

Forms [1904.29 ]• OSHA Form 300, Log of Work‐Related Injuries and Illnesses• OSHA Form 301, Injury and Illness Incident Report• OSHA Form 300A, Summary of Work‐Related Injuries and 

Illnesses

YES

YES

NO

1

OSHA’s NINE OFFICIAL EXCEPTIONS TO WORK RELATEDNESS

1. At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee.

2. The injury or illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside the work environment.

3. The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball.

4. The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption (whether bought on the employer’s premises or brought in). For example, if the employee is injured by choking on a sandwich while in the employer’s establishment, the case is not work-related. Note: If the employee is made ill by ingesting food contaminated by workplace contaminants (such as lead), or gets food poisoning from food supplied by the employer, the case is work-related.

5. The injury or illness is solely the result of an employee doing personal task (unrelated to their employment) at the establishment outside of the employee’s assigned working hours.

6. The injury or illness is solely the result of personal grooming, self-medication for a non-work-related condition, or is intentionally self-inflicted.

7. The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work.

8. The illness is the common cold or flu (Note: contagious diseases such a tuberculosis, brucellosis, hepatitis A, or plague are work-related if the employee is infected at work).

9. The illness is a mental illness. Mental illness is not work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a work-related mental illness.

2

If a work-related injury or illness results in medical treatment beyond first aid, you must record it on the OSHA 300 Log.

For this rule, medical treatment does not include:

• Visits to a physician or other LHCP solely for observation or counseling

• Diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications solely for diagnostic purposes (e.g., eye drops to dilate pupils).

Medical treatment” is the management and care of a patient to combat disease or disorder.

The rule identifies what is NOT considered medical treatment. If the treatment is not listed on the official OSHA list of first aid treatments, it is considered medical treatment.

What about medical treatment?What about medical treatment?

If the employee received medical treatment but remained at work without transfer or restriction and the injury or illness did not involve death, one or more days away from work, one or more days of restricted work, or one or more days of job transfer, you enter a check mark in the box for other recordable cases.

NOTE: You must record the case even if the injured or ill employee does not follow the physician or other licensed health care professional’s recommendation.

3

14 First Aid Treatments – no more and no less!!

1. Using nonprescription medications at nonprescription strength (for medications available as both prescription and non-prescription drugs. A recommendation by a physician or other licensed health care professional to use a non-prescription drug at prescription strength is considered medical treatment for recordkeeping purposes.

2. Administering tetanus or diphtheria immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment.)

3. Cleaning, flushing or soaking wounds on the surface of the skin.

4. Using wound coverings such as bandages, Band-Aids, gauze pads, butterfly bandages, Steri-Strips, etc. (other wound closing devices such as sutures, staples, etc. are considered medical treatment.)

5. Using hot or cold therapy.

6. Using any non-rigid means of support such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes.)

7. Using temporary immobilization devices while transporting an accident victim (e.g. splints, slings, neck collars, back boards, etc.)

8. Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister.

9. Using eye patches.

10. Removing foreign bodies from the eye using only irrigation or a cotton swab.

11. Removing splinters or foreign material from areas other than the eyes by irrigation, tweezers, cotton swabs or other simple means.

12. Using finger guards.

13. Using non-therapeutic massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes.)

14. Drinking fluids for relief of heat disorders.