OSHA-Reportable Laboratory Injuries: The 8-Hour and 24-Hour Clocks, and What Recordable Means Instead

Reportable and recordable are two different OSHA obligations with two different triggers, and conflating them is the single most common error in secondary coverage of this topic. Reporting means telephoning or notifying OSHA directly, on a clock measured in hours, and is governed by 29 CFR 1904.39. Recording means entering the case on the OSHA 300 Log, on a seven-calendar-day clock, and is governed by 29 CFR 1904.4 through 1904.12. A laboratory injury can be one, both, or neither.

The distinction bites hardest in laboratories for two reasons that generic OSHA guidance does not address. First, most laboratory establishments are on OSHA’s partially exempt list and keep no 300 Log at all — yet the reporting duty still applies to them in full. Second, the reporting clocks are measured from the incident, not from the medical outcome, which means the delayed-onset chemical exposures that laboratories worry about most often fall outside the reporting rule entirely while remaining squarely inside the recording rule.

The two obligations at a glance

	Reporting (1904.39)	Recording (1904.4–1904.12)
What you do	Notify OSHA directly by phone, in person, or through the online application	Enter the case on OSHA Form 300 and complete a Form 301
Deadline	8 hours (fatality) or 24 hours (in-patient hospitalization, amputation, loss of an eye)	7 calendar days from receiving the information (1904.29(b)(3))
Who owes it	Every employer covered by the OSH Act, including partially exempt ones	Only employers not partially exempt under 1904.1 and 1904.2
Trigger	Four specific outcomes, within a window measured from the incident	Any work-related new case meeting the general criteria of 1904.7
State-plan variation	May be more stringent or supplemental (1904.37(b)(2))	Must be the same as federal (1904.37(b)(1))

Reporting: the 8-hour and 24-hour clocks under 1904.39

29 CFR 1904.39(a) sets exactly two deadlines and four triggering outcomes:

• Within 8 hours after the death of any employee as a result of a work-related incident, you must report the fatality to OSHA.
• Within 24 hours after the in-patient hospitalization of one or more employees, or an employee’s amputation, or an employee’s loss of an eye, as a result of a work-related incident, you must report that event to OSHA.

There is no third clock and no other reportable outcome. A chemical burn, a solvent inhalation event, a laceration from broken glassware, a cryogenic injury or a needlestick is reportable only if it produces one of those four outcomes inside the applicable window — regardless of how serious it looks, how much medical attention it draws, or how much it costs.

How to make the report

1904.39(a)(3) gives three permitted methods: by telephone or in person to the OSHA Area Office nearest the incident site; by telephone to OSHA’s toll-free number, 1-800-321-OSHA (1-800-321-6742); or by electronic submission through the reporting application on osha.gov. 1904.39(b)(1) closes the obvious loophole: if the Area Office is closed, you may not leave a voicemail, send a fax, or send an email — you must use the 800 number or the online application. For a fatality on a Friday evening in an unstaffed building, that rule is the whole answer.

1904.39(b)(2) lists the eight items OSHA will ask for: the 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 the incident. A laboratory that pre-stages those eight fields in its emergency-response procedure will not spend the eighth hour of a fatality clock hunting for a building address and a NAICS-coded establishment name.

“In-patient hospitalization” is narrower than it sounds

This is the definition most often misstated, and 1904.39 defines it twice for emphasis:

• 1904.39(b)(9): OSHA defines in-patient hospitalization as a formal admission to the in-patient service of a hospital or clinic for care or treatment.
• 1904.39(b)(10): you do not have to report an in-patient hospitalization that involves only observation or diagnostic testing. You must only report each in-patient hospitalization that involves care or treatment.

Two consequences follow directly. A researcher taken to an emergency department, held overnight on a chemical-exposure observation protocol, monitored, and discharged the next morning without treatment is not a reportable in-patient hospitalization — the admission was for observation. But a researcher formally admitted for treatment, even briefly, is. The question is not how long they were in the building; it is whether there was a formal admission to the in-patient service and whether care or treatment was given. Ask the treating facility for the admission status, not for the length of stay.

“Amputation” is defined; “loss of an eye” is not

1904.39(b)(11) gives an explicit definition and an explicit exclusion list. An amputation is the traumatic loss of a limb or other external body part. It includes a part that has been severed, cut off, or amputated completely or partially; fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; and amputations of body parts that have since been reattached. It excludes avulsions, enucleations, deglovings, scalpings, severed ears, and broken or chipped teeth.

Note the interaction that the exclusion list creates. Enucleation — surgical removal of the eye — is expressly not an amputation. But loss of an eye is its own separate reportable category under 1904.39(a)(2), so an enucleation following a laboratory incident would ordinarily be reported under that category rather than as an amputation. That is a reading of the regulatory text, not a quotation from it: 1904.39 does not define “loss of an eye” anywhere. Borderline cases — permanent loss of vision from an alkali or acid splash where the globe is not removed, for instance — are not resolved by the text of the rule, and a laboratory facing one should call the Area Office rather than infer an answer. See the site’s guide to eyewash station and safety shower requirements for the upstream control that keeps this question hypothetical.

The trap: which event starts the clock

Almost every secondary summary of 1904.39 states the 8-hour and 24-hour deadlines and stops. The paragraph that actually decides most laboratory cases is 1904.39(b)(6), which sets an outer eligibility window measured from the incident:

You must only report a fatality to OSHA if the fatality occurs within thirty (30) days of the work-related incident. For an in-patient hospitalization, amputation, or loss of an eye, you must only report the event to OSHA if it occurs within twenty-four (24) hours of the work-related incident. However, the fatality, in-patient hospitalization, amputation, or loss of an eye must be recorded on your OSHA injury and illness records, if you are required to keep such records.

So there are two distinct time concepts, and they are routinely collapsed into one:

	Eligibility window (1904.39(b)(6))	Reporting deadline (1904.39(a), (b)(7), (b)(8))
Measured from	The work-related incident	The event itself, or the moment you or your agent learn of it, or the moment you learn it was work-related
Fatality	Death must occur within 30 days of the incident	8 hours
Hospitalization, amputation, loss of an eye	The event must occur within 24 hours of the incident	24 hours
If the window is missed	No report is owed	—

1904.39(b)(7) and (b)(8) handle late knowledge and are the reason a laboratory should not treat a missed deadline as automatic. If you do not learn about a reportable event at the time it takes place, the 8-hour or 24-hour clock runs from when it is reported to you or to any of your agents. If you do not learn right away that the event was work-related, the clock runs from when you or your agent learn that. In a university department where a graduate researcher goes to a hospital independently and the principal investigator learns of it three days later, the clock starts on the day the department learns — provided the underlying event still satisfies the (b)(6) window measured from the incident.

Two more carve-outs worth knowing

• Motor vehicle (1904.39(b)(3)). An event resulting from a motor vehicle accident on a public street or highway, outside a construction work zone, is not reportable — but it is still recordable if you keep records. Relevant to field sampling, courier transport of specimens and inter-campus sample runs.
• Commercial or public transport (1904.39(b)(4)). Events occurring on an airplane, train, subway or bus are not reportable, but remain recordable. Relevant to conference and field-station travel.

Delayed-onset chemical exposures: why the 24-hour window is the whole question

Laboratories handle agents whose serious effects appear after the initial contact rather than during it. Hydrofluoric acid is the canonical example; certain isocyanates, phosgene, nitrogen oxides, alkali splashes to the eye, and several sensitizers behave in the same general way, with the clinically significant deterioration arriving after the worker has already left the bench. The regulatory consequence is stark and often the opposite of what people assume.

Because 1904.39(b)(6) measures the window from the work-related incident — the splash, the spill, the release — and not from the exposure’s clinical effect, the sequence determines everything:

Scenario	Reportable?	Recordable?
Splash on Monday; formally admitted for treatment Monday evening	Yes — hospitalization occurred within 24 hours of the incident. Report within 24 hours of the admission.	Yes
Splash on Monday; symptoms escalate; formally admitted for treatment Thursday	No — the hospitalization did not occur within 24 hours of the incident	Yes
Splash on Monday; taken to hospital Monday night for observation only, discharged Tuesday	No — observation without care or treatment is excluded by 1904.39(b)(10)	Depends on whether 1904.7 criteria are met
Inhalation exposure Monday; death on day 12	Yes — within the 30-day fatality window. Report within 8 hours of learning.	Yes
Inhalation exposure Monday; death on day 45	No — outside the 30-day window	Yes

Two practical points follow. First, “not reportable” never means “nothing happened.” Every one of the non-reportable rows above is still a recordable case for an employer that keeps records, and 1904.39(b)(6) says so explicitly in its own text. Second, the failure mode in a laboratory is almost always the opposite of a late report: it is a chemical hygiene officer who correctly reports a delayed hospitalization out of caution, and then never opens a 300 Log entry because the case was already “handled.” OSHA does not penalise an unnecessary report. It does cite a missing log entry.

This page does not state a latency period for hydrofluoric acid or any other agent. Onset behaviour depends on concentration, route, surface area and decontamination, and the operative source for a specific product is its safety data sheet plus an occupational-medicine or poison-control consultation — not a compliance guide. What the regulation fixes is the clock, and the clock starts at the incident. For the upstream handling controls, see reactive chemicals handling and how to read a safety data sheet.

Recording: the 300 Log criteria

1904.4(a) sets three cumulative tests. A case must be recorded if it is (1) work-related, (2) a new case, and (3) meets one or more of the general recording criteria of 1904.7 or the specific criteria of 1904.8 through 1904.12.

Work-relatedness (1904.5)

An injury or illness is work-related if an event or exposure in the work environment either caused or contributed to the condition, or significantly aggravated a pre-existing condition. Work-relatedness is presumed for anything resulting from events or exposures in the work environment unless a specific exception at 1904.5(b)(2) applies. The work environment includes not only physical locations but the equipment or materials used by the employee during work — which places a reagent, an instrument and a glove firmly inside it.

Two of the nine exceptions matter regularly in laboratories: a case is not work-related if the person was present as a member of the general public rather than as an employee (relevant to visitors, and to the separate question of whether unpaid students are employees at all), or if signs and symptoms merely surface at work but result solely from a non-work exposure outside it. Note also the express carve-back at exception (iv): an illness from ingesting food contaminated by workplace contaminants such as lead is work-related.

New case (1904.6)

A case is new if the employee has not previously had a recorded injury or illness of the same type affecting the same body part, or had one but recovered completely and a workplace event or exposure caused the signs or symptoms to reappear. For chronic occupational illness where signs recur without further exposure — 1904.6(b)(1) names occupational cancer, asbestosis, byssinosis and silicosis — the case is recorded once only. But 1904.6(b)(2) is the one that matters for laboratory sensitisers: an episode caused by a workplace event or exposure, such as an episode of occupational asthma, is a new case each time.

The six general criteria (1904.7)

A work-related new case is recordable if it results in any of: death; days away from work; restricted work or transfer to another job; medical treatment beyond first aid; loss of consciousness (1904.7(b)(6) — any duration, no minimum); or a significant injury or illness diagnosed by a physician or other licensed health care professional.

Under 1904.7(b)(7), cases involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum must always be recorded at the time of diagnosis, even with no treatment, no restriction and no lost time. For a laboratory, that clause is the recording hook for a diagnosed occupational disease arising from long-term exposure — and it is why the reporting rule’s silence about chronic illness is not a gap in the overall scheme.

Medical treatment beyond first aid — a closed list

1904.7(b)(5)(i) defines medical treatment as the management and care of a patient to combat disease or disorder, and expressly excludes three things: visits to a physician or other licensed health care professional solely for observation or counseling; diagnostic procedures such as x-rays and blood tests, including prescription medications used solely for diagnostic purposes; and first aid as defined in 1904.7(b)(5)(ii).

That first-aid definition is a fourteen-item list, and 1904.7(b)(5)(iii) states flatly that it is complete — nothing else counts as first aid. The items that decide most laboratory cases:

• Non-prescription medication at non-prescription strength is first aid. A recommendation to use it at prescription strength is medical treatment.
• Tetanus immunisation is first aid. Hepatitis B vaccine and rabies vaccine are medical treatment. This single line decides a large share of animal-facility and biosafety cases.
• Cleaning, flushing or soaking wounds on the surface of the skin is first aid — so a fifteen-minute emergency-shower rinse after a splash is not, on its own, medical treatment.
• Bandages, butterfly bandages and Steri-Strips are first aid. Sutures and staples are medical treatment.
• Removing a foreign body from the eye by irrigation or a cotton swab is first aid. Removing it by any other means is not.
• Hot or cold therapy, non-rigid supports, eye patches, finger guards, draining a blister, drilling a nail, and drinking fluids for heat stress are all first aid. Rigid immobilising devices are medical treatment.

Two anti-gaming rules sit underneath. Per 1904.7(b)(5)(iv), the professional status of whoever provides the treatment is irrelevant — a listed first-aid measure delivered by a physician is still first aid, and treatment beyond first aid delivered by anyone else is still medical treatment. Per 1904.7(b)(5)(v), if a clinician recommends medical treatment and the employee declines it, you must record the case anyway.

Restricted work (1904.7(b)(4))

Restricted work occurs when, because of a work-related case, you keep the employee from performing one or more routine functions of the job or from working a full shift, or a clinician recommends that. Routine functions are those the employee performs at least once per week. Three points decide laboratory cases:

• A restriction applying only to the day of the injury is not recordable (1904.7(b)(4)(iii)).
• A restriction is recordable only if it actually affects a routine function. Barring a cell-culture researcher from operating a centrifuge they use monthly is not restricted work; barring them from the biosafety cabinet they use daily is.
• Vague instructions such as “light duty” must be clarified with the clinician. If you cannot get clarification, 1904.7(b)(4)(vii) requires you to record the case as restricted work.

Needlesticks and sharps (1904.8)

1904.8(a) is a stricter, standalone trigger: you must record all work-related needlestick injuries and cuts from sharp objects contaminated with another person’s blood or other potentially infectious material, as defined in the Bloodborne Pathogens Standard at 1910.1030(b). No treatment, lost time or restriction is required — contamination alone makes it recordable. The definition expressly reaches laboratory cultures and tissues from experimental animals infected with HIV or HBV.

By contrast, a cut from a clean object or a non-OPIM contaminant is recordable only if it meets the general 1904.7 criteria. A splash exposure without a cut is recordable as an illness only if it results in a diagnosed bloodborne illness or meets 1904.7. And under 1904.8(b)(3), if a recorded injury is later diagnosed as an infectious bloodborne disease, you must update the log — reclassifying the case from injury to illness and revising the description. Needlesticks are also privacy concern cases under 1904.29(b)(7)(v), so the employee’s name must not appear on the 300 Log. For the response side, see the first-hour needlestick protocol.

Medical removal (1904.9)

If an employee is medically removed under the medical surveillance requirements of an OSHA standard, the case must be recorded — as days away or restricted work, depending on how you comply — and where the removal results from chemical exposure, it is entered in the poisoning column. 1904.9(b)(2) notes that not all standards have medical removal provisions, and names lead, cadmium, methylene chloride, formaldehyde and benzene among those that do. 1904.9(b)(3) is the counterpart: a voluntary removal, made before a standard’s removal criteria are met, is not recordable.

Where the Laboratory Standard interacts with this — and where it does not

It does not supersede Part 1904. 29 CFR 1910.1450(a)(2) provides that where the Laboratory Standard applies it “shall supersede, for laboratories, the requirements of all other OSHA health standards in 29 CFR part 1910, subpart Z.” Part 1904 is a separate part of Title 29 and is not a Subpart Z health standard, so the supersession does not reach the recording or reporting duties at all. A laboratory operating entirely under a Chemical Hygiene Plan owes the same 1904.39 report and, if not partially exempt, the same 300 Log as any other workplace.

Where the two do meet is at medical consultation, and the interaction cuts the way most people do not expect. The Laboratory Standard requires an opportunity for medical consultation and examination in defined circumstances, including after a spill, leak or explosion creating the likelihood of hazardous exposure. But 1904.7(b)(5)(i)(A) and (B) exclude from “medical treatment” both visits made solely for observation or counseling and the conduct of diagnostic procedures such as blood tests. Sending a researcher for the Chemical Hygiene Plan’s post-incident medical consultation does not, by itself, make the case recordable. The case becomes recordable if that consultation produces treatment beyond first aid, a work restriction, days away, or a significant diagnosis — not because the consultation happened.

One area the regulatory text does not settle cleanly: 1910.1450(a)(2)(iii) can pull a substance-specific standard’s exposure-monitoring and medical-surveillance provisions back into a laboratory where the action level, or absent one the PEL, is routinely exceeded. Whether a given standard’s medical-removal provisions travel with it into a laboratory use, and therefore whether a removal becomes a 1904.9 case, is not answered on the face of either rule. Confirm that with the Area Office or a current letter of interpretation rather than inferring it. See which exposure limit governs a laboratory chemical for how the action-level trigger works.

Partial exemption: most laboratories keep no 300 Log — and still owe the report

This is the asymmetry worth stating plainly, because it is where laboratories most often get the whole scheme backwards. Two partial exemptions exist:

• 1904.1 — size. If your company had 10 or fewer employees at all times during the last calendar year, you need not keep OSHA injury and illness records unless OSHA or BLS tells you in writing to. The test is company-wide peak employment, not per site.
• 1904.2 — industry. If your establishment is classified in an industry group listed in Appendix A to Subpart B of Part 1904, you need not keep records unless asked to.

Three NAICS groups on that Appendix A list cover the great majority of laboratory establishments:

NAICS	Industry	Typical laboratory it covers
5417	Scientific Research and Development Services	Independent research institutes, contract research organisations, biotech R&D sites
6113	Colleges, Universities, and Professional Schools	Academic research and teaching laboratories
6215	Medical and Diagnostic Laboratories	Standalone clinical and reference laboratories

And now the part that matters. Both exemption provisions carry the same express carve-out in their own text. 1904.1(a)(1): “However, as required by 1904.39, all employers covered by the OSH Act must report to OSHA any work-related incident that results in a fatality, the in-patient hospitalization of one or more employees, an employee amputation, or an employee loss of an eye.” 1904.2(a)(1) says the same for the industry exemption. The partial exemption is an exemption from routine recordkeeping only. It changes the reporting duty not at all.

So the practical position for a typical university laboratory is: no 300 Log, no 301 forms, no annual summary — and a live, unqualified obligation to phone OSHA within 8 or 24 hours when one of the four outcomes occurs. A compliance programme built around “we are exempt” is built on a misreading.

Three qualifications that catch people out

• The classification is of the establishment, not the laboratory. Under 1904.46, one business location normally contains one establishment, and it can be split only where the parts are distinctly separate businesses in different economic activities that no single NAICS code covers. A research laboratory inside a hospital is part of the hospital establishment — and hospitals are not on the Appendix A list, so that laboratory’s cases go on the hospital’s 300 Log. A quality-control laboratory inside a pharmaceutical manufacturing plant is likewise part of a manufacturing establishment.
• A mixed company loses the industry exemption per establishment, not overall. Per 1904.2(b)(1), some establishments in a company may be exempt while others are not.
• The exemption is conditional. Both 1904.1 and 1904.2 make it subject to OSHA or BLS notifying you in writing under 1904.41 or 1904.42. 1904.41(b)(6) and 1904.42(b)(3) confirm that on receiving such a notification a partially exempt employer must begin keeping records and submit as directed — including responding to a BLS Survey of Occupational Injuries and Illnesses.

State-plan states: same recording rules, potentially different reporting rules

Federal Part 1904 is not universal, and 1904.37 draws the line precisely — in a way that is directly relevant here because the difference falls on the reporting side:

• 1904.37(b)(1): state-plan states must have the same requirements as federal OSHA for determining which injuries and illnesses are recordable and how they are recorded. There is no state variation in the 300 Log criteria.
• 1904.37(b)(2): for other Part 1904 provisions — the rule names industry exemptions, reporting of fatalities and hospitalizations, record retention and employee involvement — state requirements may be more stringent than or supplemental to the federal ones, subject to consultation with and approval by OSHA.

So the 8-hour and 24-hour clocks in this page are the federal floor. A laboratory in a state-plan state must confirm its own state’s reporting rule, telephone number and reporting channel rather than assuming the federal text governs. 1904.37(b)(3) adds that state plans must cover state and local government employees — which brings public university laboratories inside a state-plan state’s scope in a way federal OSHA alone would not.

If you do keep records: the mechanics

• Forms (1904.29(a)). OSHA 300 (Log), 300-A (Summary) and 301 (Injury and Illness Incident Report), or equivalent forms. A 301 is required for every case entered on the 300 Log.
• Timing (1904.29(b)(3)). Enter each recordable case on the 300 Log and the 301 within 7 calendar days of receiving information that it occurred.
• Privacy cases (1904.29(b)(6)–(9)). For six categories — injury to an intimate body part or the reproductive system, injury from sexual assault, mental illness, HIV/hepatitis/tuberculosis infection, contaminated needlesticks and sharps injuries, and any other illness where the employee asks — enter “privacy case” instead of the name and keep a separate confidential list. Two of those six are routine laboratory categories.
• Annual summary (1904.32). Review the log, total the columns, and have a company executive certify it — an owner, a corporate officer, the highest-ranking company official at the establishment, or that person’s immediate supervisor. Post it from 1 February to 30 April of the following year, in a conspicuous place, unaltered.
• Retention (1904.33). Keep the 300 Log, the privacy case list, the annual summary and the 301 forms for five years after the end of the calendar year they cover, and update the stored logs during that period for newly discovered cases and changes in classification. Summaries and 301s need not be updated.
• Employee access (1904.35). You must have a reasonable reporting procedure that would not deter a reasonable employee, tell employees about it and about their right to report without retaliation, provide the current or stored 300 Log to an employee or representative by the end of the next business day, and provide a worker’s own 301 on the same next-business-day timeline. Names may not be removed from the 300 Log copy. The first copy is free.
• Government access (1904.40). Copies to an authorised government representative within four business hours of the request.
• Electronic submission (1904.41). Establishments with 20–249 employees in an Appendix A industry, and those with 250 or more employees required to keep records, submit Form 300A data annually. Establishments with 100 or more employees in an Appendix B industry also submit Forms 300 and 301 data. The deadline is 2 March of the year after the calendar year covered. 1904.41(b)(7) confirms this applies in state-plan states too.

A working decision sequence

1. Is anyone dead, formally admitted for care or treatment, missing a body part, or missing an eye? If none of the four, no report is owed. Go to step 5.
2. Did that outcome occur within the window measured from the incident? Within 30 days for a fatality; within 24 hours for the other three. If not, no report is owed. Go to step 5.
3. For a hospitalization, was there a formal admission to the in-patient service for care or treatment — not observation or diagnostic testing only? Confirm the admission status with the facility.
4. Report within 8 hours (fatality) or 24 hours (the other three), measured from the event or from when you or your agent learned of it, or learned it was work-related. Use the Area Office, 1-800-321-OSHA, or the online application — never voicemail, fax or email. Have the eight 1904.39(b)(2) data items ready. Check whether your state plan imposes anything additional.
5. Are you required to keep records at all? Check company size against 1904.1, then the establishment’s NAICS classification against Appendix A to Subpart B — remembering that the establishment, not the laboratory, is what gets classified. If exempt and not notified in writing, stop here.
6. Run the 1904.4 tests: work-related, new case, and meeting 1904.7’s general criteria or the specific criteria at 1904.8–1904.12. For a contaminated sharps injury, 1904.8 alone is enough.
7. Record within 7 calendar days, applying the privacy-case rule where it fits, and update the stored log later if the classification changes.

Frequently asked questions

Is every OSHA-reportable injury also recordable?

For an employer that keeps records, yes in practice — each of the four reportable outcomes independently satisfies a 1904.7 general criterion. The reverse is emphatically not true: the overwhelming majority of recordable laboratory cases are not reportable. And for a partially exempt employer, a reportable event may generate no log entry at all, because there is no log.

Does an emergency-room visit make an injury reportable?

No. Reportability turns on formal admission to the in-patient service for care or treatment under 1904.39(b)(9), within 24 hours of the incident. An emergency-department visit, however serious, is not by itself an in-patient hospitalization, and an admission for observation or diagnostic testing only is expressly excluded by 1904.39(b)(10).

A researcher was splashed on Monday and hospitalised on Thursday. Do I call OSHA?

Under the federal rule, no — 1904.39(b)(6) limits the reporting duty to hospitalizations occurring within 24 hours of the work-related incident. The case is still recordable if you keep records, and 1904.39(b)(6) says so in its own text. Check your state plan, which may impose a broader duty under 1904.37(b)(2).

Our university lab is partially exempt. Do we still have to call OSHA?

Yes. 1904.1(a)(1) and 1904.2(a)(1) both state expressly that all employers covered by the OSH Act must report a fatality, in-patient hospitalization, amputation or loss of an eye under 1904.39, regardless of the recordkeeping exemption.

Is a needlestick with no injury and no treatment recordable?

Yes, if the sharp was contaminated with another person’s blood or other potentially infectious material. 1904.8(a) makes contamination alone sufficient, with no treatment, restriction or lost-time requirement, and the case must be logged as a privacy case without the employee’s name.

Does the post-incident medical consultation required by our Chemical Hygiene Plan make the case recordable?

Not by itself. 1904.7(b)(5)(i) excludes visits made solely for observation or counseling and the conduct of diagnostic procedures such as blood tests from the definition of medical treatment. The case becomes recordable only if the consultation leads to treatment beyond first aid, restricted work, days away or a significant diagnosis.

Does a 15-minute emergency shower rinse count as medical treatment?

No. “Cleaning, flushing or soaking wounds on the surface of the skin” is item (C) on the closed first-aid list at 1904.7(b)(5)(ii). What follows the rinse is what decides the case.

How long do we keep the records?

Five years after the end of the calendar year they cover, under 1904.33(a), and the stored logs must be updated during that period for newly discovered cases and changes in classification.

What this page does not assert

• It states no latency period, symptom timeline or treatment protocol for hydrofluoric acid or any other agent. Those belong to the product’s safety data sheet and to occupational-medicine and poison-control sources.
• It cites no OSHA letter of interpretation. Letters of interpretation are useful and citable, but they are agency interpretation and not regulation; none was read for this page, so none is relied on. Where the rule’s text does not resolve a question — the undefined term “loss of an eye,” and whether a substance-specific medical-removal provision reaches a laboratory use through 1910.1450(a)(2)(iii) — that is said plainly above rather than papered over.
• It does not state any state plan’s specific reporting requirements. 1904.37(b)(2) permits them to be more stringent or supplemental, and they must be checked directly with the state agency.
• Nothing here is legal advice, and 1904.0’s own note applies: recording or reporting a case does not mean the employer or employee was at fault, that a rule was violated, or that the employee is eligible for workers’ compensation.

Sources

• 29 CFR Part 1904, Recording and Reporting Occupational Injuries and Illnesses — retrieved from the eCFR as of the 1 August 2026 Title 29 edition. All section quotations above are verbatim from that text.
• 29 CFR 1910.1450, Occupational Exposure to Hazardous Chemicals in Laboratories — eCFR.
• 29 CFR 1910.1030, Bloodborne Pathogens — eCFR, for the definition of other potentially infectious materials incorporated by 1904.8.

This guide sits in CASRAI’s laboratory compliance cluster alongside laboratory safety rules, the Chemical Hygiene Officer role, job hazard analysis for lab procedures and the dictionary entry for laboratory safety under the OSHA Chemical Hygiene Plan.