What Steps Should Be Taken During Incident Reporting?

When a workplace incident happens, take these eight steps in order: respond to the emergency, notify supervisors, decide whether OSHA must be notified, preserve the scene, collect information, determine root causes, implement corrective actions and record the case if it is recordable. Some steps carry legal deadlines measured in hours. Others decide whether the same incident happens again.

The legal deadlines come from OSHA's injury and illness recordkeeping and reporting rule, 29 CFR Part 1904. The investigation steps follow OSHA's own guidance document, Incident [Accident] Investigations: A Guide for Employers (December 2015), which lays out a four-step systems approach: preserve and document the scene, collect information, determine root causes and implement corrective actions.

A note on terms: OSHA's guide deliberately uses "incident" instead of "accident," because most harmful workplace events are preventable rather than random. It defines an incident as a work-related event in which an injury, ill health or a fatality occurred or could have occurred, and a close call (also called a near miss) as an incident that could have caused serious injury or illness but did not. That definition pulls near misses into your reporting process, not just injuries.

Incident Reporting, OSHA Reporting and Recordkeeping Are Three Separate Obligations

New EHS managers and operations leaders often treat these as one task. They are three separate obligations with different triggers, deadlines and audiences:

• Internal incident reporting is how employees tell you about injuries, illnesses and close calls. If you are covered by OSHA's recordkeeping rule, 29 CFR 1904.35 requires you to set up a reasonable procedure for employees to report work-related injuries and illnesses promptly and accurately, tell each employee how that procedure works, and tell employees they have the right to report and that you are prohibited from retaliating against them for reporting.
• Reporting to OSHA under 29 CFR 1904.39 applies to four severe outcomes only: a fatality, an in-patient hospitalization, an amputation or the loss of an eye. It applies to all employers covered by the Occupational Safety and Health Act (OSH Act), including employers that are exempt from keeping injury and illness records.
• Recordkeeping means entering recordable cases on the OSHA 300 Log and OSHA 301 Incident Report (or equivalent forms) and completing the annual OSHA 300A Summary. It applies to employers that are not partially exempt.

If you operate in a state with an OSHA-approved State Plan, the state's reporting and recordkeeping rules apply and can differ from the federal rules described here. Confirm your State Plan's requirements before you finalize your procedure. OSHA's State Plans page lists each plan and what it covers.

Step 1: Respond to the Emergency and Make the Scene Safe

Get injured workers medical care first. Call emergency services when the injury calls for it, provide first aid through trained responders, and stop the hazard from hurting anyone else by shutting down and isolating equipment, containing a spill or clearing the area.

OSHA's investigation guide is explicit about sequence: emergency response has to be finished, and the site has to be safe and secure, before anyone enters it to investigate. Move only what you must to rescue someone or control an ongoing hazard, and note what was moved and why. That note matters in Step 4.

If the injured worker is a temporary employee supplied by a staffing agency, notify the agency promptly. OSHA's guide says the host employer and the staffing agency should each conduct an investigation and keep each other informed.

Step 2: Notify Supervisors and Start the Internal Report

Once people are safe, the supervisor or person in charge reports the event up the chain and the first written record gets started. Capture the basics while they are fresh: who was involved, what happened, where and when it happened, what injuries or damage resulted, and who saw it. A short first notice now is more useful than a complete report two days later.

Your written procedure should spell out how and when management is notified, who is authorized to contact outside agencies such as OSHA, fire or police, and who will conduct the investigation. OSHA's guide recommends defining these elements before anything happens, because during a serious incident everyone is occupied with the emergency.

The procedure also has a legal floor for employers covered by the recordkeeping rule. Under 1904.35, a reporting procedure is not reasonable if it would deter or discourage a reasonable employee from accurately reporting a workplace injury or illness. Review any rule that ties discipline, rewards or rigid deadlines to the act of reporting against that standard. If crews need a refresher on the procedure, an accident reporting toolbox talk is a quick way to deliver one.

Step 3: Decide Whether OSHA Must Be Notified Within 8 or 24 Hours

This step has the shortest legal clock. Under 29 CFR 1904.39, you must report to OSHA:

• A work-related fatality within 8 hours. You only have to report the death if it occurs within 30 days of the work-related incident.
• A work-related in-patient hospitalization, amputation or loss of an eye within 24 hours. You only have to report these if they occur within 24 hours of the work-related incident.

The clock starts when you or any of your agents learn about the event. If you learn later that the event was work-related, the clock starts at that point instead.

How to report. Call or visit the OSHA Area Office nearest the incident, call OSHA's toll-free line at 1-800-321-OSHA (6742), or use the online reporting application at osha.gov/report. If the Area Office is closed, use the toll-free number or the online application. A voicemail, fax or email to the Area Office does not meet the requirement.

What to have ready. OSHA requires the establishment name, the location and time of the incident, the type of reportable event, the number and names of employees affected, a contact person and phone number, and a brief description of the incident. If your Step 2 first notice captured those fields, the report takes minutes.

The details that trip people up:

• "In-patient hospitalization" means a formal admission to the in-patient service of a hospital or clinic for care or treatment. An admission only for observation or diagnostic testing is not reportable.
• Amputation includes fingertip amputations with or without bone loss and body parts that have since been reattached. It does not include avulsions, enucleations, deglovings, scalpings, severed ears, or broken or chipped teeth.
• A fatality or severe injury from a motor vehicle accident on a public street or highway is not reportable unless it happened in a construction work zone. Events on commercial or public transportation, such as an airplane, train, subway or bus, are not reportable either. Both still have to be recorded if you keep OSHA records.
• A work-related fatality or in-patient hospitalization caused by a heart attack is reportable. The local OSHA Area Office director decides whether to investigate.
• Small employers are not exempt from this step. The partial exemption for companies with 10 or fewer employees covers recordkeeping, not severe injury reporting.

Step 4: Preserve and Document the Scene

The first step in OSHA's four-step investigation approach is to preserve and document the scene before evidence is moved, cleaned up or repaired. Use cones, barrier tape or a guard posted at the area to keep it intact, and hold off on restarting the line until the scene is documented.

Record the investigation basics (the date and the names of the investigators) and the incident facts: the injured employee's name, a description of the injury, whether the employee is temporary or permanent, and the date and location of the incident. Then capture the physical scene:

• Photos: Start with distance shots and move closer, shoot from several angles, and place an object of known size in the frame for scale. Log the date, time, location and photographer for each image.
• Video: Record early, scan slowly in a full circle and narrate what you are filming.
• Sketches: Include measurements from fixed reference points such as a wall or column, compass directions, where people were at the time of the incident and where each photo was taken.

OSHA's guide recommends keeping an investigator's kit ready at all times, including a camera, charged batteries, measuring devices, warning tape, marking cones, PPE, sealable evidence containers and blank investigation forms, so this step doesn't wait on a supply run.

Step 5: Collect Information and Interview Witnesses

The second step in OSHA's approach is collecting information through interviews and records. Interview the injured worker and witnesses as soon as the site is safe and things have settled, because memory fades and early statements tend to be more accurate and candid. Expect to re-interview people, up to and including senior managers, as new facts come out.

OSHA's guide recommends these interview practices:

• Conduct the interview in the employee's language, with a translator if needed.
• State clearly that the purpose is fact-finding, not fault-finding.
• Let the employee know they can have an employee representative present, if one is available.
• Ask the person to describe what happened in their own words, and don't interrupt.
• Get permission before recording the interview.
• Read back the facts you collected and correct any inconsistencies.
• Ask what the person thinks could have prevented the incident.

Interviews are only part of the record. Pull the documents that show how the system was working before the incident: equipment manuals, maintenance schedules and logs, training records, company policies, audit and follow-up reports, and earlier corrective action recommendations, including any that were never completed.

Step 6: Determine the Root Causes

The third step in OSHA's approach is determining root causes. OSHA describes root causes as the underlying reasons an unsafe condition existed or a procedure or safety rule was not followed, and notes that they generally reflect management, design, planning, organizational or operational failings. A damaged machine guard that was never repaired is a root cause. The worker reaching past it is not.

The working method is to keep asking why. "Employee did not follow the procedure" is a starting point, not a conclusion. Why didn't they? The task was behind schedule. Why was it behind schedule? A second operator had been pulled to another line. Why was the task allowed to run short-staffed? Each answer moves the investigation away from the worker closest to the event and toward the conditions that made the event likely.

OSHA's guide calls this a systems approach and contrasts it with treating incidents as simple human error. Investigations aimed at assigning blame stop short of the root causes, and they discourage the open participation that investigations depend on. Areas to examine include procedures, equipment condition and design, hazardous conditions, PPE selection and use, workspace layout, staffing, supervision and training.

OSHA's guide also recommends investigating as a team instead of leaving it to the supervisor alone. Managers and frontline employees bring different knowledge to the same facts, and shared ownership makes the resulting corrective actions more likely to stick.

[SME QUOTE PLACEHOLDER: 1 to 2 sentences from a named EHS subject matter expert on the most common root cause shortcut they see, such as closing investigations at "human error." Attribute with full name and title.]

Step 7: Implement and Track Corrective Actions

The fourth step in OSHA's approach is implementing corrective actions, and the guide is direct that an investigation is not complete until corrective actions that address the root causes are in place. A reminder to "wear your PPE" or a finding that someone "should have used common sense" will not prevent the next incident.

Make each corrective action specific enough to verify:

• Tie it to a root cause. Every root cause from Step 6 should have at least one action that addresses it.
• Favor stronger controls. The hierarchy of controls published by the National Institute for Occupational Safety and Health (NIOSH) ranks elimination, substitution and engineering controls ahead of administrative controls and PPE. Where a stronger control is feasible, it should come first.
• Assign an owner and a due date. Actions without an owner tend to reappear as findings in the next investigation.
• Verify effectiveness. After the action is complete, confirm the hazard is controlled, not just that the task was marked closed.
• Share the findings. Communicate lessons learned to similar work areas, and to the staffing agency or other employers on site when the incident involved a temporary worker or a multi-employer worksite.

Step 8: Record the Case and Review Trends

If your company is required to keep OSHA injury and illness records, decide whether the case is recordable and enter it on the OSHA 300 Log and OSHA 301 Incident Report (or equivalent forms) within 7 calendar days of receiving information that a recordable injury or illness has occurred. That deadline runs in parallel with the investigation, so don't wait for the root cause analysis to close before recording.

Under 29 CFR 1904.7, a work-related injury or illness is recordable if it results in any of the following:

• Death
• Days away from work
• Restricted work or transfer to another job
• Medical treatment beyond first aid
• Loss of consciousness
• A significant injury or illness diagnosed by a physician or other licensed health care professional

Two groups are partially exempt from routine recordkeeping: companies that had 10 or fewer employees at all times during the last calendar year, and establishments in certain lower-hazard industries listed by NAICS code in Appendix A to Subpart B of Part 1904. Partially exempt employers still have to report severe injuries under Step 3, and they have to keep records if OSHA or the Bureau of Labor Statistics notifies them that they must.

Recordkeeping carries follow-on obligations. You must keep the 300 Log, 300A Summary and 301 forms for five years following the end of the calendar year they cover. When an employee, former employee, personal representative or authorized employee representative asks for a copy of the relevant 300 Log, you must provide it by the end of the next business day. Certain establishments must also submit injury and illness data electronically through OSHA's Injury Tracking Application (ITA) based on establishment size and industry, so check OSHA's recordkeeping page for the current submission requirements.

Finally, look across incidents, not only at each one. OSHA's guide recommends an annual review of the incident investigation program to identify incident trends and correct program weaknesses. Trending incidents by location, task, equipment and root cause category shows where to focus prevention work.

Why Near Misses Belong in Your Incident Reporting Process

OSHA does not require you to report near misses to the agency, and a close call with no injury or illness is not recordable. OSHA's investigation guide still strongly encourages employers to investigate close calls, because they expose the same hazards and program gaps as injury incidents without anyone getting hurt.

Near miss reporting depends on how easy and how safe it feels to report. Many safety programs keep the near miss form short, accept reports from anyone, and tell the person who reported what changed as a result. For high-potential near misses, use the same root cause and corrective action steps you would use for a serious injury.

Common Incident Reporting Mistakes to Avoid

• Misreading "hospitalization." Treatment in an emergency room followed by release is not an in-patient hospitalization. A formal admission for care or treatment is.
• Leaving a voicemail at a closed Area Office. It does not count. Use 1-800-321-OSHA or the online application.
• Holding the 300 Log entry until the investigation closes. The 7-day recording clock runs on its own schedule.
• Ending the investigation at "human error." OSHA's guide treats human error as the start of the analysis, not the finding.
• Closing corrective actions without verifying them. A completed task is not the same as a controlled hazard.
• Leaving the staffing agency out. For temporary workers, both the host employer and the agency should investigate and share what they find.

How EHS Insight Supports Incident Reporting and Investigation

Each step above produces information that has to be captured, routed and acted on, often by different people. The EHS Insight Incident Management module centralizes that work for everything from near misses to recordable incidents:

• Fast first notice. When the First Report setting is enabled, a user can submit a brief first notice of a reportable event so stakeholders can be notified early. A user with the Submit role then completes the full Incident Event form, and linked First Report fields carry forward so information isn't entered twice.
• One event, multiple consequences. A single Incident Event can capture injury, illness, asset, environmental, security and near miss consequences, along with witness details, attachments and location data where those fields are enabled.
• Configurable workflow. Workflows can include submission, up to three approval levels, investigation assignment and review, classification, final review and closure, with configurable due periods for submission, approval and classification.
• Structured root cause analysis. Configurable investigation methodologies capture immediate, underlying and root causes with categories and filtering, and organizations can set up two methodologies, such as a basic and a comprehensive investigation.
• Connected corrective actions. CAPAs can be created directly from incident findings and tracked through closure.
• Serious incident tracking. Incidents can be classified as Significant Injuries and Fatalities (SIF), with notifications to a defined group of users and reporting on SIF trends.
• OSHA recordkeeping output. OSHA 300, 300A and 301 reports are generated from Incident Event and Injury/Illness Classification data, and ITA export files can be produced in a format compatible with OSHA's Injury Tracking Application.

One boundary is worth stating plainly: software helps you capture, track and document incidents, but the 8-hour and 24-hour notifications under 1904.39 are still made by phone, in person or through OSHA's online application. Your procedure should name the person responsible for making that report.

Frequently Asked Questions About Incident Reporting

What Are the Steps in Incident Reporting?

Respond to the emergency and make the scene safe, notify supervisors and start the internal report, decide whether OSHA must be notified, preserve and document the scene, collect information and interview witnesses, determine root causes, implement corrective actions, and record the case on OSHA forms if it is recordable.

How Soon Do You Have to Report a Workplace Injury to OSHA?

Under 29 CFR 1904.39, report a work-related fatality within 8 hours and a work-related in-patient hospitalization, amputation or loss of an eye within 24 hours. Other injuries are not reported to OSHA directly, but if you are required to keep OSHA records, recordable cases must be entered on the OSHA 300 Log within 7 calendar days.

Do Near Misses Have to Be Reported to OSHA?

No. OSHA's reporting rule covers only fatalities, in-patient hospitalizations, amputations and losses of an eye, and a near miss with no injury or illness is not recordable. OSHA strongly encourages employers to investigate near misses anyway.

Do Small Businesses Have to Report Serious Injuries to OSHA?

Yes. Companies with 10 or fewer employees at all times during the last calendar year are partially exempt from keeping OSHA injury and illness records, but every employer covered by the OSH Act must report fatalities, in-patient hospitalizations, amputations and losses of an eye under 29 CFR 1904.39.

Is an Overnight Hospital Stay for Observation Reportable to OSHA?

No. OSHA defines in-patient hospitalization as a formal admission for care or treatment. An admission only for observation or diagnostic testing does not have to be reported under 1904.39, although the case may still be recordable on the OSHA 300 Log.

What Is the Difference Between an Incident Report and an OSHA 301?

An internal incident report is your company's own record of what happened and can cover near misses, property damage and environmental events. The OSHA 301 Injury and Illness Incident Report is required for each recordable injury or illness from employers that keep OSHA records. Your internal form can be used in place of the 301 if it contains the same information.

Get More From Every Incident Report

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