1. Purpose and Scope
This Standard Operating Procedure (SOP) defines how facilities operated by [Organisation Name] respond to, report, and record occupational injuries and illnesses.
This procedure applies to all direct employees and temporary personnel under the day-to-day operational supervision of [Organisation Name]. The organisation logs recordable incidents for eligible temporary workers on its own log.
The [Primary Recordkeeper Job Title] manages all compliance requirements and deadlines outlined in this procedure. The [Deputy Recordkeeper Job Title] acts as the secondary administrative owner.
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2. Regulatory Obligations: Reporting vs. Recording
Occupational safety regulations under 29 CFR Part 1904 establish two separate administrative requirements:
- Mandatory External Reporting: Applies to all employers, regardless of company size or industry exemption status. Notify the Occupational Safety and Health Administration (OSHA) or the relevant State Plan agency immediately for severe workplace incidents:
- Fatalities: Report within eight (8) hours of learning of the event.
- Inpatient Hospitalizations, Amputations, or Loss of an Eye: Report within twenty-four (24) hours of learning of the event.
- Mandatory Recordkeeping: Requires logging eligible workplace injuries and illnesses on the official log (OSHA Form 300) and completing an individual incident report (OSHA Form 301).
- Applies to organisations with more than ten (10) employees operating in non-exempt industry sectors.
- Recordable events include work-related cases resulting in death, days away from work, restricted work activity, job transfer, medical treatment beyond first aid, loss of consciousness, or significant conditions diagnosed by a licensed healthcare professional.
- Entering an incident on the log does not mean the company admits fault, negligence, or a regulatory violation.
- Internal Event Tracking: Incidents requiring only first aid are not recordable on regulatory logs. However, staff must log all workplace incidents, regardless of severity, in the internal tracking system at [System/Location] to help identify hazards and prevent future incidents.
- Determination of Recordability: If a case’s status is unclear, the [Primary Recordkeeper Job Title] must review regulatory guidelines and document the rationale for the final decision.
3. Immediate Incident Response Workflow
- Render Aid and Secure Medical Care: Provide immediate on-site first aid, arrange transport to [Designated Medical Clinic], or call emergency services (911) for severe conditions. Medical care takes priority over paperwork.
- Secure the Scene: For severe events, the immediate supervisor must secure the incident location. Leave physical evidence undisturbed unless moving it is necessary to treat injured personnel or eliminate immediate hazards. The supervisor must notify the [Primary Recordkeeper Job Title] right away.
- Employee Notification: The affected worker, or a witness if the worker is incapacitated, must report the incident to their supervisor before the end of the shift.
- Internal Incident Reporting: The supervisor must complete and submit the internal incident report in [System/Location] within [Timeframe]. Include the people involved, location, timestamp, witness statements, and initial causes.
- Initial Screening: The [Primary Recordkeeper Job Title] must review the case on the day it occurs to confirm recordability and identify statutory reporting deadlines.
4. Reporting Severe Injuries to Regulatory Authorities
- Verify Incident Outcome: Confirm that the event is work-related and meets the criteria for external reporting (fatality, inpatient hospitalization, amputation, or eye loss).
- Monitor Statutory Clocks: Track mandatory notification deadlines (8 hours for fatalities; 24 hours for hospitalization, amputation, or eye loss), starting the moment [Organisation Name] learns of the incident.
- Compile Submission Data: Gather required details before calling or submitting online:
- Legal business entity name and facility location
- Date, time, and specific location of the event
- Nature of the incident and description of injuries
- Number and names of affected personnel
- Designated organizational contact person and phone number
- Submit Notification: Report details to the regulatory body through one of these channels:
- Direct phone call to the nearest area office during business hours
- The central 24-hour telephone hotline
- The official online web portal
- Note: In State Plan jurisdictions, submit reports directly to the state regulatory authority following local regulations.
- Document Communication: Record the submitting official’s name, recipient details, date, timestamp, and confirmation or control numbers in the incident file.
- Initiate Internal Response: Brief the [Senior Executive Job Title] and start the internal investigation. Keep the scene secure until inspecting regulatory authorities release it.
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5. Completing the Incident Log (Form 300) and Incident Report (Form 301)
- Log Entry Timeline: Enter each recordable case on OSHA Form 300 within seven (7) calendar days of receiving notice of the event. Use current official forms.
- Categorization and Narrative: Classify each case under a single outcome category (death, days away from work, job transfer/restriction, or other recordable case). Write a clear description of the specific injury, affected body part, and event cause.
- Form 301 Completion: Complete an OSHA Form 301 Incident Report (or an approved equivalent, such as a state Workers’ Compensation First Report of Injury containing identical data fields) for every logged entry.
- Tracking Lost and Restricted Days: Count days away from work and restricted duty periods using regulatory rules. Update log entries as medical outcomes progress or change.
- Secure Record Storage: Store medical records and case documentation at [Secure Location/System]. Keep these records separate from general personnel files, and restrict access to [Authorized Job Titles].
- Monthly Reconciliation: Reconcile the OSHA Form 300 log monthly against internal tracking data and workers’ compensation claims logs to maintain accurate records.
6. Annual Summary (Form 300A) and Data Submissions
- Summary Calculation: At the end of each calendar year, the [Primary Recordkeeper Job Title] must total the entries on the OSHA Form 300 log and transfer the sums to the OSHA Form 300A Annual Summary. Enter zero for categories with no recordable events.
- Executive Certification: A company executive ([Senior Executive Job Title]) must review the log for accuracy and sign the Form 300A certification statement.
- Mandatory Posting: Post a copy of the certified Form 300A in designated employee communication areas from February 1 through April 30 of the year following the recordable period.
- Electronic Data Submission: Review organizational submission requirements every January. If [Organisation Name] meets the headcount and industry risk criteria for mandatory electronic reporting, submit Form 300A data (and Form 300/301 data, if applicable) through the official online portal by the regulatory deadline.
- Record Retention: Keep Form 300 logs, Form 301 reports, and certified Form 300A annual summaries for five (5) years following the end of the calendar year covered. Store archived files at [Secure Location/System].
7. Privacy Protections and Employee Access
- Privacy-Concern Cases: For sensitive incidents defined by regulation (such as injuries to intimate body parts, mental health conditions, or sexual assault), enter “Privacy Case” instead of the employee’s name on Form 300. Maintain a separate confidential key linking the case number to the individual’s identity.
- Access Rights: Current employees, former personnel, and their authorized personal representatives may inspect the OSHA Form 300 log and relevant portions of Form 301 reports by submitting a request to the [Primary Recordkeeper Job Title].
- Anti-Retaliation Policy: [Organisation Name] strictly prohibits discipline, discrimination, or retaliation against any worker for reporting an occupational injury, illness, or safety hazard. The organisation bans safety incentive programs or administrative practices that discourage prompt reporting.
8. Records and Review
| Requirement | Details |
|---|---|
| Document Owner | [Primary Recordkeeper Job Title] |
| Deputy Owner | [Deputy Recordkeeper Job Title] |
| Storage Location | [Secure Location/System] |
| Retention Period | 5 years following the end of the calendar year covered |
| Review Schedule | [Annual / Periodic] |
| Trigger Events for Review | Regulatory updates, post-inspection evaluations, or changes in internal processes |
| Next Review Due | [Date] |
FAQs on an OSHA injury reporting and recordkeeping procedure
What is an OSHA injury reporting and recordkeeping procedure?
An OSHA injury reporting and recordkeeping procedure defines how facilities operated by your organisation respond to, report, and record occupational injuries and illnesses.
Having it written down means the same rules apply to everyone, so managers are not making judgement calls case by case under pressure.
What does an OSHA injury reporting and recordkeeping procedure include?
This template covers regulatory obligations: reporting vs. recording, immediate incident response workflow, reporting severe injuries to regulatory authorities and completing the incident log (form 300) and incident report (form 301).
Every section is written to be filled in. The bracketed placeholders mark the decisions that are yours to make, such as timescales, approval owners and retention periods.
How to implement an OSHA injury reporting and recordkeeping procedure with Whale
Copy this template into Whale and work through the bracketed placeholders so it reflects how your organisation actually operates.
Assign it to the teams it applies to so it sits where people work rather than in a shared drive, and set a review date so it gets revisited on schedule instead of quietly going out of date.
Use our templates to fast-track your documentation
Customize this template and 100s of others for free in Whale, the fastest way to get your team aligned.