OSHA recordkeeping and injury reporting for small contractors

Two duties that small owners often confuse

OSHA's injury rules in 29 CFR Part 1904 contain two different obligations. Recordkeeping means keeping a log of work-related injuries and illnesses on OSHA forms, investigating each case and posting a yearly summary. Reporting means calling or notifying OSHA quickly when a worker is killed or seriously injured. Small companies can be exempt from the first. Nobody is exempt from the second.

The small-company exemption is narrow in another way too: it is based on the number of employees in the entire company, not at one shop or yard^[1]. A contractor with two small branches that each have seven people counts fourteen. And the exempt employer must still report any incident involving a fatality, an in-patient hospitalization, an amputation or the loss of an eye^[1].

Who must keep injury logs

The size test is simple to state and easy to get wrong. If your company had 10 or fewer employees at all times during the last calendar year, you are partially exempt from keeping injury and illness records. If you had more than 10 employees at any time during the last calendar year, you must keep them unless your industry is on OSHA's list of partially exempt industries^[1]. Count part-time, seasonal and temporary employees you supervise day to day, not just full-timers.

Many home service businesses sit right around that line. Census data show that 76.8% of plumbing, heating and air-conditioning contractor establishments and 85.0% of landscaping establishments had fewer than ten employees in 2023^[4]. Those are establishment counts, not company counts, but they show how many firms live near the threshold, and how a few seasonal hires in spring or a second location can change the answer.

• Check your peak headcount for the previous calendar year each January, across all locations.
• Include seasonal crew members, part-timers and temps you direct, even if they worked only a few weeks.
• Look up whether your industry code appears on OSHA's partially exempt industries list before assuming you are exempt.
• If you crossed the threshold, start the OSHA 300 log for the current year immediately.

Severe injury reporting deadlines

These deadlines apply to every employer covered by OSHA, regardless of size. A fatality must be reported within 8 hours. An in-patient hospitalization, amputation or loss of an eye must be reported within 24 hours^[2]. You can report by calling your nearest OSHA area office, by calling OSHA's 24-hour hotline at 1-800-321-6742, or through OSHA's online serious event reporting form^[2].

Write the hotline number and the rule on the inside of every truck's door and in your safety binder. Name who in the company makes the call, with a backup for nights and weekends. The clock starts when the employer learns of the event, so the field supervisor must call the office immediately, not at the end of the shift.

What makes an injury recordable

Not every scrape goes on the log. Under the general recording criteria, a work-related injury or illness is recordable if it results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness, or if it is a significant injury or illness diagnosed by a physician or other licensed health care professional.

• Usually first aid only, not recordable: non-prescription medication at non-prescription strength, tetanus shots, cleaning or soaking surface wounds, hot or cold therapy, eye patches, bandages and simple splints for transport.
• Usually recordable: stitches, prescription medication, a doctor telling the worker to stay home or avoid certain tasks, a fracture, or any lost-time injury.
• Gray areas: ask whether treatment went beyond first aid and whether the worker could do all normal duties the next day.

Decide recordability from the facts and the regulation's definitions, not from whether the worker filed a workers' compensation claim. The two systems overlap but are not the same.

The yearly recordkeeping cycle

1. 01

   During the year

   Record each recordable case on the OSHA 300 log and complete an incident report (Form 301 or an equivalent) promptly after you learn of it.

2. 02

   At year end

   Review the log for accuracy, total the cases and complete the annual summary (Form 300A).

3. 03

   Certification

   A company executive must certify that they have examined the log and that the summary is correct. For a sole proprietorship or partnership, that can be an owner^[3].

4. 04

   Posting

   Post the summary no later than February 1 of the year after the one it covers, and keep it posted until April 30, where employees normally see notices^[3].

5. 05

   Storage

   Keep the log, summary and incident reports for the retention period set in 29 CFR 1904.33, counted from the end of the year they cover.

6. 06

   Electronic submission

   Check whether your establishment size and industry require you to submit data to OSHA electronically each year.

For a company with mobile crews, post the summary at the shop or yard where crews start their day, and send a copy to anyone who does not report there. Many owners also email it to all staff, which helps when people work mostly from their trucks.

Why the numbers matter in the trades

Home service work carries real risk. BLS counted 5,070 fatal work injuries in the US in 2024, and construction and extraction occupations accounted for 1,032 of them, including 370 from falls, slips and trips^[5]. OSHA reports that 389 of 1,034 construction fatalities in 2024 were falls to a lower level^[6]. A good log is the cheapest way to see your own patterns before they become one of those numbers: ladder injuries in the spring rush, strains from lifting equipment, cuts from sheet metal or heat illness in July.

Setting up a simple incident process

1. Every injury, however minor, is reported to a supervisor the same day, by phone or in the field app.
2. The supervisor records what happened, where, the task, tools and conditions, with photos.
3. The office decides whether the case is first aid or recordable, using the definitions, and logs recordable cases.
4. Severe events trigger the OSHA call within the deadline and a call to your workers' compensation carrier.
5. Each case gets a short corrective action: a ladder replaced, a lift assist added, a procedure changed.
6. Once a quarter, review the log and corrective actions in a team meeting.

Many states run OSHA-approved State Plans that can have their own reporting rules and forms. If you operate in a State Plan state, check its rules as well as the federal ones.

Example: seasonal hiring crosses the line

Example (fictional): a landscaping company has eight year-round employees. In 2026 it adds five seasonal crew members from April to October, reaching thirteen. In January 2027, the owner checks peak headcount for 2026, sees that the company had more than 10 employees at some point, and starts an OSHA 300 log for 2027. In June a crew member cuts a hand on a mower blade and needs stitches; the office logs it as recordable and adds blade-handling gloves to every trailer. In August a worker is hospitalized overnight for heat illness, and the owner reports it to OSHA within 24 hours. In January 2028 the owner certifies and totals the summary and posts it at the yard by February 1.