"reporting non-occupational injury and illness"

For non-occupational injuries and illnesses, the core OSHA recordkeeping rule is that only work-related cases belong on the OSHA 300 Log, 300A Summary, and 301 Incident Report. A non-work-related injury or illness is therefore generally not OSHA-recordable, even if the employee receives medical treatment or files a workers’ compensation claim. Employers should still have an internal incident-reporting process so supervisors can document the facts, determine work-relatedness, preserve confidentiality, and decide whether any other legal or benefit reporting applies. [4] [9]

In practice, employers should separate OSHA recordkeeping from internal reporting and medical documentation.

• Require employees to promptly report any injury or illness event, including events believed to be off-duty or non-work-related, to a supervisor or designated contact so the employer can evaluate whether work exposure contributed to the case.
• Document the initial report with date, time, employee statement, where the event occurred, symptoms, witnesses, and whether any work activity, exposure, travel, or workplace violence issue may have contributed.
• If the case is determined to be work-related and otherwise recordable, complete OSHA Form 301 or an equivalent within 7 calendar days of learning of the case and enter it on the OSHA 300 Log.
• If the case is determined to be non-work-related, keep the employer’s internal report and any benefit or leave documentation, but do not place it on the OSHA log unless later facts show a work connection.
• Protect medical confidentiality and limit access to health information to those with a business or legal need to know.

[3] [4] [9] For medical treatment documentation, OSHA Form 301 or an equivalent incident report is the standard record for recordable work-related cases. Equivalent workers’ compensation or insurance forms may be used if they contain the same required information. The form should capture the treating provider, off-site treatment location, emergency-room treatment, inpatient hospitalization status, and a clear description of what the employee was doing, what happened, the injury or illness, and the object or substance involved. Even when a case is ultimately found to be non-occupational, using a similar internal form is a best practice because it supports consistent work-relatedness determinations and later review if facts change. [4] [9] [9]

For first aid cases, OSHA recordability depends on whether the case is work-related and whether it involves only first aid or instead medical treatment beyond first aid, days away, restricted work, job transfer, loss of consciousness, or another recording criterion. If a case is non-work-related, it is not OSHA-recordable regardless of treatment. If it is work-related and the only care provided is OSHA-defined first aid, it is generally not recordable unless another recording criterion applies. [7] [7] [8]

Examples of OSHA first aid treatments include:

• Nonprescription medication at nonprescription strength
• Tetanus immunizations
• Cleaning, flushing, or soaking surface wounds
• Bandages, gauze, butterfly bandages, or Steri-Strips
• Hot or cold therapy
• Elastic wraps or other non-rigid support
• Temporary immobilization during transport
• Draining a blister or drilling a nail to relieve pressure
• Eye patches or irrigation/cotton-swab removal of foreign bodies from the eye
• Simple splinter removal, finger guards, massage, and fluids for heat stress

[7] A workers’ compensation claim does not by itself decide OSHA recordability. Workers’ compensation systems and OSHA recordkeeping serve different purposes and use different standards. Employers may use workers’ compensation first reports or insurance forms as equivalent documentation for a recordable case if they contain the required information, but they should not assume that every workers’ compensation case is OSHA-recordable, or that every non-compensable case is non-recordable. For non-work-related injuries and illnesses, workers’ compensation generally does not apply unless state law recognizes some employment connection. [4] [6]

For employee reporting procedures, employers should maintain a clear, reasonable reporting system and must not retaliate against employees for reporting work-related injuries or illnesses. Employees should be told who receives reports, how to report after hours, what immediate medical response steps to follow, and what documentation is required. This is especially important where temporary workers are used, because the host employer and staffing agency should coordinate reporting responsibilities and exchange medical information needed for recordkeeping when the host supervises day to day. [1] [5] [5]

For regulatory compliance, employers should keep in mind that OSHA’s reporting and electronic submission rules apply to covered establishments’ work-related injury and illness records, not to purely non-occupational cases. Covered employers may have to submit OSHA 300A, 300, and 301 data electronically depending on establishment size and industry, while partially exempt employers generally do not routinely submit unless specifically notified. If a case is not work-related, it should not be included in those OSHA submissions. [1] [1] [2]

1. Receive the employee report promptly and provide needed first aid or medical referral.
2. Determine whether the case is work-related. If it is clearly non-occupational, do not enter it on OSHA 300/300A/301.
3. If facts are unclear, investigate promptly, interview the employee and witnesses, and review work tasks, exposures, travel status, and timing before deciding.
4. Document the determination in writing, including why the case was classified as non-work-related.
5. If the case is work-related and recordable, complete Form 301 or equivalent within 7 calendar days, enter the case on the OSHA 300 Log, and retain required records.
6. Maintain supporting documents such as supervisor reports, clinic notes, first-aid logs, and any equivalent workers’ compensation or insurance forms.
7. Train employees on how to report injuries and illnesses and prohibit retaliation for reporting.
8. Review state-specific workers’ compensation, leave, and privacy rules, because those may still require documentation or reporting even when OSHA recordkeeping does not.

[9] [6] [1]