Navigating OSHA Recordkeeping and BLS Injury Reporting Requirements




Ensuring workplace safety and compliance with federal regulations is paramount for employers. Two critical components in this endeavor are understanding the Occupational Safety and Health Administration (OSHA) recordkeeping requirements and the Bureau of Labor Statistics (BLS) injury and illness reporting obligations.

OSHA Recordkeeping Requirements

OSHA mandates that employers maintain records of work-related injuries and illnesses. However, there is a partial exemption for some employers with 10 or fewer employees. According to OSHA standard 1904.1, if your organization had 10 or fewer employees at all times during the last calendar year, you are not required to keep OSHA injury and illness records unless specifically informed otherwise. It's essential to note that this exemption applies to recordkeeping requirements; all employers must still report any workplace incident that results in a fatality or the hospitalization of three or more employees.

BLS Injury and Illness Reporting

The BLS conducts the Survey of Occupational Injuries and Illnesses (SOII) annually to gather data on workplace incidents. Participation in the SOII is mandatory for selected employers. OSHA's recordkeeping regulations require employers to report injury and illness data to the BLS when informed in writing to do so. The BLS uses widely accepted statistical methods to select a sample of establishments annually to participate in the SOII. This data collection helps in understanding industry trends and formulating safety regulations.

Key Takeaways

  • Recordkeeping Exemption: Some, but not all, employers with 10 or fewer employees may be exempt from maintaining OSHA injury and illness records but must still report severe incidents.

  • Mandatory Reporting: If selected by the BLS for the SOII, employers are required to provide the requested injury and illness data.

The OSHA "10 or More Employee" Partial Exemption refers to specific recordkeeping exemptions under the Occupational Safety and Health Administration (OSHA) regulations. Here's what you need to know:

What is the Partial Exemption?

Under OSHA’s recordkeeping rules (29 CFR 1904), employers with 10 or fewer employees at all times during the previous calendar year are partially exempt from maintaining certain OSHA injury and illness records, such as:

  • OSHA 300 Log (Injury and Illness Log)
  • OSHA 300A (Summary of Work-Related Injuries and Illnesses)
  • OSHA 301 (Injury and Illness Incident Report)

However, these small businesses must still report serious injuries, illnesses, and fatalities to OSHA, as required.

Who Qualifies for the Partial Exemption?

✅ Businesses that had 10 or fewer employees at all times during the previous calendar year.
✅ Applies to the total number of employees company-wide, not per location.
✅ Some industries, regardless of size, are always required to maintain records due to higher workplace risks (e.g., healthcare, construction, manufacturing).

What Are Employers Still Required to Do?

Even if your business qualifies for the exemption, you must still:

  1. Report Severe Injuries to OSHA:
    • Within 8 hours: Work-related fatalities.
    • Within 24 hours: Work-related amputations, loss of an eye, or hospitalization of an employee.
  2. Follow OSHA Safety Standards – All employers must comply with general OSHA safety regulations.
  3. Provide a Safe Workplace – Employers must ensure workplace safety and adhere to hazard communication, PPE, and other safety protocols.

Where Can You Check Your Industry’s Requirements?

  • OSHA’s Exempt List: OSHA Partially Exempt Industries
  • NAICS Code Lookup: Use OSHA’s NAICS code search tool to see if your industry is exempt from full recordkeeping.

Navigating these regulations can be complex. For personalized guidance tailored to your organization's needs, contact BizCoachGurus at BizCoachGurus@gmail.com.

Sources:

  1. OSHA Recordkeeping Requirements – Occupational Safety and Health Administration (OSHA)
    https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.1

  2. BLS Injury and Illness Reporting FAQs – Bureau of Labor Statistics (BLS)
    https://www.bls.gov/respondents/iif/faqs.htm

For expert guidance on compliance with workplace safety regulations, contact BizCoachGurus at BizCoachGurus@gmail.com.

Contact us today at BizCoachGurus.com to learn how we can help you build a workforce that stays and succeeds!

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