Scope of injury recordkeeping

All employers covered by the Occupational Safety and Health Act (OSH Act) are covered by the part 1904 regulations. The rule makes clear that part 1904 applies to every employer who falls under the OSH Act even if that employer may later be exempted from keeping certain records. See the 1904 Subpart B (Scope) statement of coverage.

No — most employers do not have to keep OSHA injury and illness records unless they are told to do so in writing by OSHA or the Bureau of Labor Statistics (BLS). The scope explains that although all employers are covered by part 1904, the recordkeeping requirement normally applies only when OSHA or BLS provides written notification that the employer must keep records. See 1904 Subpart B (Scope).

It means employers with 10 or fewer employees are generally treated differently for the recordkeeping requirements and may not have to keep OSHA injury and illness records unless otherwise notified. The scope explains that employers with 10 or fewer employees are among those who are partially exempt from maintaining OSHA injury and illness records, subject to written notification requirements from OSHA or BLS. See 1904 Subpart B (Scope).

It means that some establishments—based on their industry classification—are identified as not normally required to keep OSHA injury and illness records, though this is a partial exemption and can be changed by written notice. The scope refers to establishments in specified industry classifications as being partially exempt from recordkeeping; those exemptions are applied by establishment and are subject to written notification from OSHA or BLS. See 1904 Subpart B (Scope).

A written notification from OSHA or the Bureau of Labor Statistics (BLS) triggers the employer's legal requirement to keep OSHA injury and illness records. The scope states that most employers do not have to keep records unless OSHA or BLS informs them in writing that they must do so. See 1904 Subpart B (Scope).

If OSHA or BLS provides written notification, your employer must maintain the OSHA injury and illness records required by part 1904. The scope makes clear that written notice from OSHA or BLS establishes the obligation to keep records under the regulation. See 1904 Subpart B (Scope).

No — the subpart does not present a list of employers who are completely exempt; it explains that most employers do not have to keep records unless notified and that some employers or establishments are partially exempt (for example, those with 10 or fewer employees or certain industry classifications). For full details on exemptions and how they apply, refer to the standard and any written notifications from OSHA or BLS. See 1904 Subpart B (Scope).

Yes — exemptions are applied at the establishment level, so one business establishment may be partially exempt while another in the same company may not be. The scope refers to "business establishments in certain industry classifications" as being partially exempt, which indicates that the exemption can be specific to an establishment's classification. See 1904 Subpart B (Scope).

Yes — even if an establishment's industry is normally partially exempt, OSHA or BLS can require recordkeeping by providing written notice. The scope states that workplaces in certain industry classifications are partially exempt from keeping records unless OSHA or BLS informs them in writing that they must keep records. See 1904 Subpart B (Scope).

Not automatically stated here, but employers with more than 10 employees are not covered by the "10 or fewer" partial-exemption reference, so they are less likely to fall under that specific partial exemption and may be required to keep records unless otherwise exempt by industry classification or notified in writing. The scope identifies employers with 10 or fewer employees as a group that is partially exempt and explains that written notice from OSHA or BLS determines recordkeeping obligations. See 1904 Subpart B (Scope).

OSHA or the Bureau of Labor Statistics must notify the employer in writing for the recordkeeping requirement to be triggered. The scope explicitly says an employer must be informed in writing by OSHA or BLS before the general rule requiring recordkeeping applies to most employers. See 1904 Subpart B (Scope).