A press operator caught his hand in a die at 10:40 on a Tuesday night. The shift supervisor drove him to the emergency room and left a voicemail for the plant manager. At 11:15 the hospital called the supervisor to say they were admitting the operator for surgery on two fingers. The supervisor wrote it on the shift handover sheet and drove home. At 6:40 the next morning the EHS manager read the handover sheet, opened an incident record, and started lining up a root-cause meeting. Nobody called OSHA. The reporting window had been running for seven hours by then.
Reporting gets missed most often when the injury happens overnight and off site, on a clock nobody in the building is watching.
Recording and reporting are two different obligations
The OSHA 300 log is recordkeeping, with its own criteria and deadlines. Reporting under 29 CFR 1904.39 is a phone call, and the deadline is measured in hours.
Within 8 hours after the death of an employee as a result of a work-related incident, you must report the fatality. Within 24 hours after the in-patient hospitalization of one or more employees, an employee’s amputation, or an employee’s loss of an eye, you must report that. Size does not get a site out of it. Employers with 10 or fewer employees are partially exempt from recordkeeping, and so are establishments in the low-hazard industry groups listed in Appendix A to Subpart B of Part 1904, which spells out the consequence: all employers, including those partially exempted by reason of company size or industry classification, must still report a fatality, in-patient hospitalization, amputation or loss of an eye. Either exemption also lifts if OSHA, BLS or a state agency asks in writing for records.
When the 24 hours actually start
The timing gets counterintuitive at paragraph (b)(7). If you do not learn about a reportable event when it happens, the period runs from the moment the event is reported to you or to any of your agents, and a shift supervisor will generally count as an agent. In the scenario above the 24 hours began at 11:15 on Tuesday night, when the hospital called the supervisor. Where the open question is work-relatedness rather than the event itself, (b)(8) starts the clock when you or an agent learns the answer.
So the design problem is a notification path that works at 11 p.m. from a hospital parking lot, run by someone who does not need permission to make the call.
What triggers the call
Two definitions and two conditions do most of the work here. OSHA defines in-patient hospitalization as a formal admission to the in-patient service of a hospital or clinic for care or treatment. The observation carve-out sits at (b)(10): an admission involving only observation or diagnostic testing is not reportable. A timing condition at (b)(6) is easy to read past, and it cuts in your favor. A hospitalization, amputation or loss of an eye is only reportable if it occurs within 24 hours of the work-related incident, and a fatality only if it occurs within 30 days. Events falling outside those windows still go on your injury and illness records if you keep records.
REPORTABLE TO OSHA UNDER 1904.39?
| Situation | Report? |
|---|---|
| Death of an employee occurring within 30 days of the work-related incident | Yes, within 8 hours |
| Formal admission to the in-patient service for care or treatment, occurring within 24 hours of the incident | Yes, within 24 hours |
| Admission that involves only observation or diagnostic testing | No |
| Amputation within 24 hours of the incident, including a fingertip with or without bone loss, a partial amputation, a medical amputation from irreparable damage, or a part since reattached | Yes, within 24 hours |
| Avulsion, enucleation, degloving, scalping, severed ear, broken or chipped tooth | Not as an amputation, since (b)(11) excludes these. An enucleation is still reportable as a loss of an eye |
| Work-related heart attack causing in-patient hospitalization or death | Yes. The Area Office director decides whether to investigate |
| Motor vehicle crash inside a construction work zone | Yes |
| Motor vehicle crash on a public street or highway, outside a construction work zone | No, but record it if you keep records |
| Event on a commercial or public transportation system, such as an airplane, train, subway or bus | No, but record it if you keep records |
Source: eCFR, 29 CFR 1904.39. Retrieved September 2026.
OSHA concedes the observation question is hard even with the file in front of it. The data limitations section of the agency’s 2022 and 2023 summary of severe injury reports notes that its dataset may include some hospitalizations that did not actually meet the threshold, and gives two examples: cases where there was not enough information to confirm the worker was admitted as an in-patient for treatment rather than observation within 24 hours, and cases where the worker may only have been seen in the emergency department as an outpatient. An EHS manager on the phone at midnight will not infer it either. Ask the hospital in those words.
What the reports look like in aggregate
Establishments under federal OSHA reported 19,690 in-patient hospitalizations and amputations across 2022 and 2023, which the agency puts at an average of 27 severe injuries and illnesses per day. That is consistent with the first year of the program in 2015 and below the 2018 peak of 31 per day. No eye losses were reported in either year.
MOST REPORTED EVENT TYPES IN SEVERE INJURY REPORTS
In-patient hospitalizations and amputations reported to federal OSHA, 2022 and 2023 combined. Counts and shares as published by OSHA. Most reports from OSHA-approved state plan jurisdictions are not included.
Source: OSHA, 2022 and 2023 Summary of Severe Injury Reports. Retrieved September 2026.
Machinery was the largest single source of injury at 4,548 reports, 25 percent on OSHA’s count, though that figure comes from a separate source-of-injury table rather than the event table charted above. OSHA’s food processing spotlight shows what those look like on the floor: of 440 reports involving food processing machinery, 75 percent involved an amputated finger or fingertip, and the narratives run heavily to unjamming and cleaning. Watch the scope. This dataset covers establishments under federal enforcement authority, roughly half of US workers, so most reports from state plan jurisdictions are absent even though those states run reporting requirements of their own.
How the call is made
Three methods are accepted: telephone or in person to the OSHA Area Office nearest the incident site, telephone to 1-800-321-OSHA (1-800-321-6742), or electronic submission through the reporting application on osha.gov. After hours, (b)(1) rules out the workaround most sites reach for. If the Area Office is closed, a voicemail, a fax or an email does not count, and you use the 800 number or the online form.
OSHA asks for eight specific items: establishment name, the location of the incident, the time of the incident, the type of reportable event, the number of employees affected, their names, your contact person and phone number, and a brief description of what happened. That is a trivial list to read off an incident record and a brutal one to assemble from memory at 6:40 in the morning.
What to put in place before the next one
Steps to Take Before You Need Them
One person who can report without clearing it first, and someone who covers nights and weekends. Put both numbers on the same card as the OSHA 800 number, in the guard shack and in every supervisor’s phone.
The 24 hours run from when a supervisor is told. Whoever arranges the ambulance or the ride owes the on-call caller a message before the end of the shift.
Was the worker formally admitted to the in-patient service for care or treatment, or held for observation or diagnostic testing? Record the answer and the name of the person who gave it.
The time of the work-related incident, and the time of the admission, amputation or eye loss. Both windows in 1904.39 turn on the gap between them.
Establishment, location, time, event type, number of employees, names, contact person, description. Assemble them once, when the incident is opened.
Several of the events you never have to phone in still belong on the 300 log. Treat the reporting decision and the recording decision as two separate reviews of the same event.
How Q-Incident Can Help
Steps four, five and six are data capture problems, and that is where the module earns its place. The incident form takes the date and time of the event alongside the establishment and a cascading location picker, so the timestamp the (b)(6) windows are measured from lands on the record at intake instead of getting reconstructed a week later. The people involved with their roles, the description and the photos sit on the same record, covering the eight items OSHA asks for on the call, and the one-click full incident report pulls them into a single PDF. Reporting can start from a QR code that opens the form with no login. On the recording side, the injured-person record carries a recordable flag that opens the OSHA 300 and 301 questions, and the 300, 300A and 301 forms export from that same data.
The judgment stays with a named human. Nothing in Q-Incident can tell you whether an overnight admission was for care or for observation, and it will not dial the Area Office or file the electronic report for you. What it can do is make sure that when the human picks up the phone, every fact OSHA asks for is already written down with a time on it. If you are building that intake discipline across more than one program, the wider EHS platform is where the shared employee, location and establishment data comes from.
