OSHA Daily Report Requirements: A Superintendent's Guide

Most crews don’t get in trouble with OSHA because they “don’t care.” They get in trouble because OSHA daily report requirements get mixed up with OSHA injury logs, and the paperwork ends up incomplete, late, or inconsistent. The good news: compliance is doable if you separate what OSHA actually requires (29 CFR 1904) from what a solid daily report should capture to protect you during an audit.

Table of Contents

• What OSHA Actually Requires
• The OSHA 300 Log Explained
• Injury Reporting Timelines
  • 24-hour requirement
  • 7-day requirement
• What Goes in Your Daily Report for OSHA
• Common Violations (And How to Avoid Them)
• Documentation Best Practices
• When You're Exempt
• FAQ

What OSHA Actually Requires

Let’s clear the air first: OSHA does not require a “daily report.” There’s no rule in 29 CFR 1904 that says you must write a superintendent daily log.

What OSHA does require (for most construction employers) falls into a few buckets under 29 CFR Part 1904 (Recording and Reporting Occupational Injuries and Illnesses):

• Recordkeeping: keeping OSHA injury/illness records (OSHA 300, 300A, 301) if you’re covered.
• Serious incident reporting: notifying OSHA within specific timelines for fatalities and certain severe outcomes.
• Timely recording: entering recordable cases on the log within a set number of days.
• Retention and availability: keeping records for years and providing them when required.

This is why the confusion happens on real projects. Your daily report isn’t the official OSHA log, but it’s often the best evidence you have when someone asks:

• “When did the incident happen?”
• “What was the weather and site condition?”
• “Who was supervising and which subs were onsite?”
• “What corrective action did you take?”

Two common field scenarios:

• Scenario 1: Slip on muddy access path. Your daily report shows it rained at 10 a.m., you had 18 workers onsite, the access path was getting tracked out, and you assigned laborers to refresh stone at lunch. That context can matter if the incident gets reviewed later.
• Scenario 2: Ladder incident with a sub. Your daily report shows toolbox talk topic was ladder safety, the sub’s foreman attended, and you noted missing ladder tags and asked the foreman to replace them. That’s not a “get out of jail free card,” but it’s strong documentation that you were managing safety.

Practical takeaway:

• Treat OSHA record keeping construction as the “official ledger.”
• Treat your construction safety documentation (daily reports, checklists, photos) as your “backup”—what proves the story is accurate.

The OSHA 300 Log Explained

The OSHA 300 log is a specific form with a specific purpose: it’s your ongoing record of work-related injuries and illnesses that meet OSHA’s recordability criteria.

Here’s the important distinction superintendents should keep straight:

• OSHA 300 log = formal, regulated record (when required) under 29 CFR 1904.
• Daily report = project documentation tool; not mandated by OSHA, but often used in audits, investigations, and claims.

What forms are in the “300 family”?

• OSHA Form 300: Log of Work-Related Injuries and Illnesses.
• OSHA Form 301: Injury and Illness Incident Report (more detail on each case).
• OSHA Form 300A: Summary (posted annually if you’re required to keep records).

What typically triggers an entry on the OSHA 300 log?

This isn’t legal advice, but generally the 300 log is for cases beyond “first aid only,” such as:

• Days away from work
• Restricted work or transfer
• Medical treatment beyond first aid
• Loss of consciousness
• Significant diagnosed injury/illness

Two field examples where contractors get tripped up:

• Example 1: “It was just stitches.” Stitches are medical treatment (not first aid). That’s often recordable. If your daily report only says “minor cut—handled,” you’ll regret it later because it hides the severity and timing.
• Example 2: “He came back the next day, so we didn’t log it.” If the doctor gave restrictions (no lifting, no kneeling) and you modified duties, it may be recordable as restricted work—even if the employee is physically onsite.

Practical takeaway:

• Your daily report should capture the facts (what happened, when, where, who, immediate actions). Your safety manager or office can decide log recordability, but they can’t do it well if your field notes are vague.

Injury Reporting Timelines

OSHA draws a hard line between recording (putting it on your OSHA 300/301) and reporting (calling OSHA). Your daily report supports both because it timestamps what you knew and when.

Under 29 CFR 1904.39, certain severe events must be reported directly to OSHA.

Two scenarios to keep straight:

• Scenario 1: Serious fall, ambulance transport. You’ll have a dozen moving parts—patient care, securing the area, talking to GC, preserving evidence. Your daily report should still capture the basics that same day.
• Scenario 2: Injury seems minor, then worsens. The initial daily report might note “sprain—first aid.” Two days later it becomes a hospitalization. If you didn’t document the timeline, your reporting clock becomes hard to defend.

24-hour requirement

OSHA requires employers to report to OSHA within 24 hours of learning about a work-related:

• In-patient hospitalization
• Amputation
• Loss of an eye

That “within 24 hours” is a common miss in construction because:

• Hospitalization status changes after an ER visit (observation vs in-patient admission).
• The employer hears about it late (Friday night, weekend, different supervisor).

Two practical examples:

• Example 1: “Admitted overnight.” A worker goes to the ER at 4 p.m. and gets admitted at 10 p.m. If you learn of the admission at 7 a.m. next day, your 24-hour clock starts when you learn of the in-patient hospitalization—not when the incident occurred.
• Example 2: Finger injury becomes amputation. Initially it’s “crush injury.” Later the doctor determines amputation is required. The 24-hour reporting clock starts when you learn it’s an amputation.

Practical takeaway:

• Add a daily report note whenever medical status changes: “ER visit,” “released,” “admitted,” “restricted duty,” “follow-up scheduled.” Those details prevent missed reporting windows.

7-day requirement

Separate from reporting to OSHA is the requirement to record qualifying injuries/illnesses on the OSHA 300 log.

Under 29 CFR 1904.29, employers must enter each recordable injury/illness on the OSHA 300 log within 7 calendar days of receiving information that a recordable injury/illness has occurred.

This is where daily reports help the office avoid late entries.

Two examples:

• Example 1: “We didn’t find out until payroll.” A foreman hears about a clinic visit but doesn’t tell anyone. Payroll sees a workers’ comp note later. Now you’re past 7 days and you’re trying to reconstruct what happened.
• Example 2: Modified duty on the sly. A worker self-restricts (only sweeping, no lifting) without a doctor note. If you document “worker placed on light duty pending evaluation,” the safety manager can investigate recordability immediately.

Practical takeaway:

• Build a habit: if anyone leaves the site for medical evaluation, make sure your daily report includes time left, where they went, and who was notified.

What Goes in Your Daily Report for OSHA

Again, OSHA doesn’t mandate daily reports. But if you’re trying to meet OSHA documentation requirements construction in the real world, your daily report is your best daily capture of safety-related facts.

Here’s what a superintendent daily report should include specifically to support OSHA record keeping construction and incident reporting.

1) Who was onsite (and doing what)

• Headcount by company/trade
• Key activities by area (roofing, steel erection, excavation)
• Visitors (inspectors, owners, utility reps)

Real-world examples:

• Example 1: Multi-employer site. If an incident involves a sub’s employee, your daily report shows the sub was onsite, the work area, and who their foreman was.
• Example 2: Short-staffed day. If you ran a skeleton crew, it matters. Less supervision + compressed schedule is a common factor in incidents.

Immediate takeaway:

• Add a simple line: “Onsite: 6 carpenters (ABC), 4 electricians (SparkCo), 2 operators (EarthWorks). Work: decking L2, rough-in L1, trenching east run.”

2) Safety meetings, pre-task planning, and toolbox talks

• Topic
• Who led it
• Which trades attended
• Any key reminders or changes to the plan

Real-world examples:

• Example 1: Hot work. You document: “Hot work briefing—fire watch assigned, extinguishers staged, permits verified.” If a small fire occurs, you’ve got proof you planned.
• Example 2: Lift plan change. Crane pick moved due to wind; you document the decision and the new setup.

Immediate takeaway:

• Don’t write “toolbox talk held.” Write: “Toolbox talk: trench safety + access/egress; tailgate at 6:30; foremen signed roster.”

3) Site conditions and controls

• Weather (especially if it affects safety: wind, rain, ice, heat)
• Ground conditions (mud, unstable soil, standing water)
• Housekeeping and access
• Traffic control

Real-world examples:

• Example 1: High winds. You stop aerial lift work at 25+ mph gusts and switch to interior tasks. Document that call.
• Example 2: Heat day. You implement water breaks and shade. Document start time changes and hydration reminders.

Immediate takeaway:

• Add one sentence: “Conditions: overcast, rain 11–2, access road muddy; added stone at gate and regraded laydown.”

4) Inspections and corrective actions

• What you inspected (scaffolds, trenches, ladders, GFCIs, fire extinguishers)
• What you found
• What you fixed
• Who you assigned

Real-world examples:

• Example 1: Missing trench box tabulated data. You document “stopped work until data onsite; foreman retrieved documentation.”
• Example 2: Damaged extension cord. You document “tagged out and removed from service; replaced with new cord.”

Immediate takeaway:

• Use a repeatable format: “Observed → Action → Responsible party → Time completed.”

5) Incident/near-miss notes (facts only)

For any incident—even a near miss—capture:

• Time and location
• People involved (and employer)
• What happened (brief)
• Immediate response
• Notifications made
• Photos taken (if allowed)

Real-world examples:

• Example 1: Near miss, dropped tool. Note barricades, overhead protection, and the corrective action (tool lanyards, exclusion zone).
• Example 2: Minor cut. Note first aid, whether the worker returned to full duty, and whether they sought medical evaluation.

Immediate takeaway:

• Avoid blame language in the daily report. Keep it factual: “Worker stepped onto uneven grade and twisted ankle” reads better than “Worker wasn’t watching where he was going.”

Common Violations (And How to Avoid Them)

Most OSHA paperwork problems come from a few repeat mistakes. They’re usually not evil—they’re just busy-jobsite mistakes.

1) Missing the 8-hour fatality report

Under 29 CFR 1904.39, a work-related fatality must be reported to OSHA within 8 hours of the employer learning of it.

Where this goes wrong:

• The incident happens Friday, the death occurs later, and nobody treats it as an OSHA reporting trigger.
• The company assumes the hospital will report it (they won’t handle your obligation).

Two examples:

• Example 1: Fatality occurs after transport. Your reporting obligation can still apply even if the death occurs later.
• Example 2: After-hours communication gap. The PM hears, but the safety manager doesn’t. No one calls OSHA.

How to avoid it:

• Establish a single “red phone” rule: if there’s a fatality or likely fatality, call the designated company contact immediately and start documenting the timeline in the daily report.

2) Confusing first aid vs medical treatment

This drives inconsistent injury reporting construction and messy logs.

Two examples:

• Example 1: Clinic visit for “just a check.” A medical evaluation can still lead to treatment beyond first aid.
• Example 2: Prescription meds. A prescription is typically medical treatment, not first aid.

How to avoid it:

• In the daily report, don’t decide recordability. Just document: “Worker sent to clinic for evaluation; returned with restrictions/no restrictions.”

3) Late OSHA 300 entries (the 7-day rule)

As noted, 29 CFR 1904.29 requires timely entries.

Two examples:

• Example 1: Sub-tier communication. A sub’s foreman doesn’t report a case until the invoice hits.
• Example 2: Weekend incidents. Someone gets treated Saturday and returns Monday with a note.

How to avoid it:

• Add a daily report habit: “Any injuries/medical visits today? Yes/No.” If yes, auto-notify the office/safety.

4) Not keeping supporting documentation

OSHA can ask questions, and you may need to show how you managed safety.

Two examples:

• Example 1: “Show your training proof.” You can’t locate toolbox talk rosters.
• Example 2: “Show your corrective action.” You noted a hazard verbally but never wrote down the fix.

How to avoid it:

• Treat daily reports + photos + inspection notes as one system. If it isn’t documented, it’s hard to defend.

Documentation Best Practices

This is the part that makes compliance achievable: reduce the mental load. Good documentation isn’t about writing more—it’s about writing the right facts consistently.

Build a simple daily safety block

Add a dedicated “Safety” section to every report. Even on a quiet day.

Include:

• Toolbox talk/pre-task plan completed (topic)
• Inspections performed (what/where)
• Hazards observed (if any)
• Corrections made (who/when)
• Injuries/near misses (yes/no + short note)

Two examples:

• Example 1: No incidents day. “Safety: toolbox talk—heat stress; inspected ladders in Area B; corrected missing guardrail at stair opening; no injuries.”
• Example 2: Busy incident day. “Safety: near miss—forklift/pedestrian at south gate; revised traffic plan; added spotter; documented briefing with delivery drivers.”

Practical takeaway:

• Make your “Safety” block the same order every day. Consistency is what makes audits survivable.

Write like an investigator will read it later

That doesn’t mean paranoid. It means clear.

Do:

• Times, locations, names/companies
• What was observed
• What action was taken
• What changed afterward

Don’t:

• Guess root cause on day one
• Admit fault or assign blame in casual language
• Use vague lines like “handled” or “taken care of”

Two examples:

• Better than “incident resolved”: “Work stopped at 2:10 p.m.; area barricaded; EMT arrived 2:25 p.m.; photos taken; statements collected by safety manager.”
• Better than “site was safe”: “Walked west scaffold run; verified toe boards installed; tagged one plank as damaged and removed.”

Practical takeaway:

• If you’re unsure, write what you saw and what you did. Save analysis for the official investigation.

Close the loop in writing

A lot of violations come from open ends.

Two examples:

• Example 1: You note “missing GFCI” but don’t note the fix. Later it looks like you ignored it.
• Example 2: You note “overhead work—barricades needed” but don’t say they were installed. Same problem.

Practical takeaway:

• End each safety item with “Completed” or “Pending” plus who owns it.

Use photos wisely

Photos are powerful for construction safety documentation, especially for temporary conditions that change daily.

Two examples:

• Example 1: Trench protection. A photo of the setup, spoil pile location, access ladder, and barricades can save you later.
• Example 2: Housekeeping and access. If you get blamed for a slip hazard that happened after your shift, time-stamped photos help.

Practical takeaway:

• Take 3–5 consistent photos daily: access points, active work zone, laydown/traffic area, and any corrected hazard.

When You're Exempt

A lot of small contractors hear “OSHA 300 log” and assume it always applies. It doesn’t.

Under 29 CFR 1904.1 and 1904.2, there are common exemptions related to:

• Company size: If your company had 10 or fewer employees at all times during the last calendar year, you’re generally exempt from routinely keeping OSHA injury and illness records (with important exceptions).
• Industry classification: Some low-hazard industries are partially exempt from routine recordkeeping based on NAICS. (Construction is generally not treated as “low hazard.”)

Important reality check:

• Even if you’re exempt from keeping the OSHA 300 log, you may still have to report severe incidents (fatalities, in-patient hospitalizations, amputations, loss of an eye) under 1904.39.
• You can also be required to keep records if OSHA or the Bureau of Labor Statistics specifically notifies you.

Two examples:

• Example 1: Small specialty contractor (9 employees). You may not keep a routine OSHA 300 log, but if there’s an in-patient hospitalization, you still have a 24-hour reporting obligation.
• Example 2: Growing contractor. You bounced between 9 and 12 employees last year. That changes your exemption status, and it’s easy to miss if you don’t track headcount.

Practical takeaway:

• If you’re near the 10-employee line, decide now who’s tracking headcount and who’s responsible for OSHA records. Don’t wait until an incident forces the question.

FAQ

Q: Are daily reports required by OSHA? A: Not directly. OSHA’s requirements in 29 CFR 1904 focus on recording/reporting injuries and illnesses (OSHA 300/301/300A and severe incident reporting). Daily reports are a best practice that supports compliance and helps you defend what happened.

Q: What’s the difference between an OSHA 300 log and a daily report? A: The OSHA 300 log is a regulated injury/illness log (when required). A daily report is your project record of labor, work, conditions, and safety actions. Daily reports help your team decide whether something is recordable and prove timelines, supervision, and corrective actions.

Q: What are the key OSHA reporting deadlines I should remember? A: Under 29 CFR 1904.39, report fatalities within 8 hours and report in-patient hospitalizations, amputations, loss of an eye within 24 hours of learning about the outcome. Separately, record recordable cases on the OSHA 300 log within 7 calendar days under 29 CFR 1904.29.

Q: If a subcontractor’s worker gets hurt on my site, do I put it on my OSHA 300 log? A: Typically, OSHA recordkeeping follows who supervises the worker on a day-to-day basis, but details can get nuanced. This isn’t legal advice—coordinate with your safety manager and follow 29 CFR 1904 guidance. Either way, your daily report should document the facts, notifications, and corrective actions on the project.

Q: What should I document the same day as an incident? A: Time/location, who was involved (and employer), what happened (facts), immediate response, who you notified, any photos taken, and what changed afterward (barricades, stop-work, retraining, equipment tagged out). Those notes make your OSHA documentation requirements construction much easier to meet later.

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