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OSHA Reporting Requirements: How should off-hour injuries be handled?


Article Contributor: Eric Schmitz

Now that dealers are required to maintain an OSHA 300 Log and the reporting requirements have changed, do you have a reporting protocol in place for all injury circumstances? Unfortunately, injuries happen at all times, even during off-business hours and on the weekends, and even after hours events may need to be reported to OSHA. If an accident does occur, do your employees know when to report and who is responsible for reporting?

Let’s take a real-life scenario of how quickly an accident can occur and reporting can be neglected: Imagine it’s a nice Saturday morning and one of your sales people, Bob, is out on the lot checking vehicle labels. An excited customer pulls into the lot, but due to the bright morning glare, can’t see well. They inadvertently drive too close to Bob and roll over his foot. Immediately after the “accident” Bob feels little pain. His adrenaline is high and his initial feeling is one of slight discomfort. The safety coordinator is off on Saturdays, but another sales person suggests that Bob go to the hospital just in case and Bob departs before the dealership is even fully open for business.

The day carries forward with a rush of customers, and within hours, everyone has forgotten about Bob’s injury. Unfortunately, it was far worse than he had initially thought. After his adrenaline wore off he found himself in greater pain and x-rays revealed great damage to his foot; he was admitted to the hospital for surgery. On Monday Bob doesn’t show up for work, prompting his co-workers to recall his injury. At this point, the safety coordinator is in and realizes that Bob’s injury was never reported to OSHA.

New OSHA reporting regulations require that “Within twenty-four (24) hours after an 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 to OSHA.” In this story line, the dealership is in violation of OSHA reporting requirements. What should be implemented at this dealership to prevent similar incidents from happening in the future?

Every dealership should have a safety coordinator. Often times, the safety coordinator is a general manager or on the management team, however, many dealerships have found great success with their safety culture when their safety coordinator is an individual who works closely with the employees who work directly on the shop floor. The safety coordinator is responsible for the safety culture at your dealership, and, in this, case, is responsible for reporting an injury and ensuring everyone knows how to respond in the event of an off-hours incident.

Everyone should have a role and a responsibility in the event of an accident. A safety coordinator can set up a schedule for those who are responsible for reporting and checking in on injured people during every shift. It is never the injured party’s responsibility to report their injury.

As a general rule of thumb, you should have a process for handling all workplace injuries.  Some facilities have had success as follows:

  • If the injury is an emergency, call 911 or take the injured party the emergency room (ER).
  • If the injury is not just first aid and not an emergency, the employee should visit the facilities designated clinic, physician, or emergency room.
  • An employee on scene should notify management or call the safety coordinator immediately.
  • Management is responsible for reporting the injury to OSHA within 24 hours of the injury.
  • Within 48 hours of occurrence an accident investigation should be completed.

Not only is it important to have a method to handle injuries during off-hours from an OSHA standpoint, it’s also important because it’s good for employees and good for business. To learn more about reporting to OSHA and recording injuries or how to assign a safety coordinator and implement a safety culture, contact

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