Safety & Accident

OSHA Injury & Illness Recordkeeping: Major Challenges, Big Benefits

October 2013, Government Fleet - Feature

by Travis Rhoden

At a glance:

Occupational Safety and Health Administration (OSHA) injury and illness recordkeeping rules vary by location and type of agency:

  • State/local government workers are not covered by a federal OSHA-approved plan in 25 states and the District of Columbia
  • State/local government workers are covered by a federal OSHA-approved plan in 25 states
  • All federal government workers are covered by OSHA’s recordkeeping regulations.


Maintaining and analyzing injury and illness records is a widely recognized method for uncovering workplace safety and health problems and for tracking progress in solving those problems. For government agencies, particularly fleets, whose workplaces often pose unique challenges, the records can be particularly useful — though determining what records must be kept and what records should be kept can be a daunting task. Knowing the requirements and the benefits of injury and illness record­keeping can help fleets stay compliant.

State & Local Government Requirements Vary

For state and local agencies and their workers, hazards are many — from garbage collection to sewer work to road and vehicle maintenance to firefighting and police work, state and local workers are exposed to numerous workplace safety hazards. Therefore, tracking workplace injuries and illnesses is critical. However, determining what injuries to track, maintaining consistency, and making sense of the data can be challenging for a variety of reasons.

➤ Some covered by OSHA, some not

One of the major challenges for state and local governments is that some are not covered by either the federal Occupational Safety and Health Administration (OSHA) rules or state-run OSHA rules. Therefore, these workplaces do not have to follow the typical OSHA injury and illness record­keeping criteria, which means they may rely on a different criteria set at the state, county, or city level. They may also have no record­keeping oversight and rely on their own internal systems. In either case, this poses an issue when trying to compare performance to similar agencies following different recordkeeping systems. It also can pose problems uncovering workplace safety issues that would otherwise be brought to light during the reporting and recordkeeping process. See Chart 1:

These states do not have Federal OSHA-approved State Plans; however, some may voluntarily have requirements that provide some protections to state/local government workers outside of the OSHA system, including injury and illness recordkeeping.
These states do not have Federal OSHA-approved State Plans; however, some may voluntarily have requirements that provide some protections to state/local government workers outside of the OSHA system, including injury and illness recordkeeping.

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