OSHA recordkeeping (Part 1904) for the CHST
Recordkeeping is where Domain 3 gets specific. The CHST blueprint lists data gathering, documentation and recordkeeping requirements, post-incident reporting and trend spotting. The rule is 29 CFR Part 1904, not Part 1926, and that detail trips people up. This guide gives the map, the deadlines and the incidence rate arithmetic, in our own words.
Check anything you rely on against your own licensed code book and the edition your AHJ enforces.
Where Part 1904 sits in the blueprint
Domain 3, safety program development, implementation and sustainment, is 22.5% of the CHST. Knowledge items 7 and 9 (recordkeeping, and post-incident reporting and follow-up) and skill item 3 (identify trends in incidents) all draw on it.
The sections to know
- 1904.4 and 1904.5 set the recording criteria and ask whether the case is work-related.
- 1904.7 gives the general recording criteria. A work-related case is recorded if it involves death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness, or if a physician or licensed health care professional diagnoses a significant injury or illness. The first aid list is in 1904.7(b)(5).
- 1904.10 covers occupational hearing loss.
- 1904.29 sets the forms: the Log (Form 300), the Incident Report (Form 301) and the Annual Summary (Form 300A). Enter a case within 7 calendar days of learning of it.
- 1904.30 covers more than one establishment, including long-running construction sites.
- 1904.32 covers the annual summary: the company executive certifies it, and it is posted from February 1 to April 30.
- 1904.33 sets retention at five years.
- 1904.35 and 1904.36 protect employee involvement and bar retaliation for reporting.
- 1904.39 sets reporting to OSHA: 8 hours for a work-related fatality, and 24 hours for an inpatient hospitalization, an amputation or loss of an eye.
- 1904.41 covers electronic submission, which depends on establishment size and industry.
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Incidence rate arithmetic
A rate puts cases on the same scale as hours worked. The formula uses 200,000 hours, which is 100 full-time workers for a year.
Total recordable case rate = (recordable cases x 200,000) / hours worked
Invented example: 4 recordable cases in 180,000 hours gives (4 x 200,000) / 180,000, or about 4.4. Check your own numbers, plus DART, lost time and severity rates, with the OSHA incident rate calculator. The DART rate uses only cases with days away, restricted work or transfer. Rates are lagging indicators: they count what already happened. Leading indicators, such as inspections completed or corrective actions closed on time, tell you what is coming.
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Common mix-ups
- Recordable is not the same as reportable. Recordable goes on the log. Reportable means telling OSHA within the 8 and 24 hour windows.
- First aid is not recordable. Medical treatment beyond first aid is. A list decides it, not the worker's opinion.
- Days away is only one trigger. A case with no lost time can still be recordable.
- Part 1904 is not Part 1926. Questions may name the wrong part to see if you notice.
How to practice
Take five invented injuries and decide which are recordable, which are reportable and why. Then compute a rate from invented hours and cases, and say which indicator type it is.
Work the incidence rate calculation in the CHST formulas guide.
Related guides: OSHA health hazards and the exam outline.
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Sources
Show the list
- 29 CFR Part 1904, Recording and Reporting Occupational Injuries and Illnesses, OSHA.
- CHST Examination Blueprint (CHST5, V.2022.04.12), Board of Certified Safety Professionals.
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