Injury and illness recordkeeping and reporting requirements
Michigan requires most employers to maintain records of work-related injuries and illnesses under MIOSHA Administrative Part 11, which adopts the federal OSHA recordkeeping framework in 29 C.F.R. § 1904. The rules govern both routine recordkeeping (Forms 300, 301, 300A) and immediate reporting of severe incidents (fatalities, hospitalizations, amputations, and loss of an eye).
## Employer coverage and exemptions
Size-based exemption. Employers with 10 or fewer employees at all times during the prior calendar year are exempt from keeping injury and illness records under R 408.22103(1)(a), unless MIOSHA, the Bureau of Labor Statistics, or federal OSHA notifies the employer in writing that records must be kept. The exemption applies company-wide, not establishment-by-establishment.
Industry-based exemption. Certain low-hazard industries listed in Appendix A to Part 11 are partially exempt from recordkeeping regardless of size, unless directed in writing to maintain records under R 408.22103(1)(b).
Universal reporting obligation. All employers covered by the Michigan Occupational Safety and Health Act—including those exempt from routine recordkeeping—must report workplace incidents that result in a fatality, inpatient hospitalization, amputation, or loss of an eye under R 408.22139.
## Recordkeeping: Forms 300, 301, and 300A
Covered employers must record each work-related injury or illness that involves death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a physician or other licensed healthcare professional (R 408.22109, R 408.22112). Minor injuries requiring only first aid are not recordable.
Form 300 (Log of Work-Related Injuries and Illnesses). Employers must log each recordable injury or illness on MIOSHA Form 300 (or the equivalent federal OSHA Form 300) within seven calendar days of receiving information that the injury or illness occurred.
Form 301 (Injury and Illness Incident Report). A detailed incident report must be completed for each recordable injury or illness within seven calendar days.
Form 300A (Summary of Work-Related Injuries and Illnesses). Employers must complete Form 300A at the end of each calendar year and post it in a conspicuous location where employees can see it from February 1 through April 30 of the following year (R 408.22132). The summary must remain accessible for the full three-month posting period.
Retention. Employers must retain Form 300 logs for five years following the year to which they relate and update them if new cases occur during the retention period (R 408.22133). Form 301 incident reports and Form 300A summaries follow the same five-year retention requirement.
## Electronic submission to OSHA
Under R 408.22141 and R 408.22141a, certain employers must submit injury and illness data electronically to federal OSHA using the Injury Tracking Application (ITA):
- Establishments with 250 or more employees in industries covered by Part 11 must submit Form 300A, Form 300, and Form 301 data annually.
- Establishments with 20 to 249 employees in designated high-hazard industries (identified by NAICS code in federal regulations) must submit Form 300A data annually.
Submissions are due by March 2 of the year following the calendar year covered by the forms (R 408.22141b).
## Immediate incident reporting to MIOSHA
R 408.22139 requires all employers covered by the Michigan Occupational Safety and Health Act to report the following work-related incidents to MIOSHA:
Fatalities. Employers must report any work-related fatality within eight hours of learning of the death. Fatalities are reported by calling the MIOSHA fatality line at 800-858-0397.
Inpatient hospitalizations, amputations, and loss of an eye. Employers must report any work-related inpatient hospitalization (admission to a hospital for treatment or observation), amputation (traumatic loss of a limb or other external body part), or loss of an eye within 24 hours of the incident. These incidents may be reported by calling the MIOSHA injury report line at 844-464-6742, through the online reporting system at the MIOSHA recordkeeping website, or in person or by telephone to the nearest MIOSHA office.
"Inpatient hospitalization" under R 408.22106(1) means formal admission to a hospital for treatment or observation, not merely an emergency department visit or outpatient procedure.
The 24-hour reporting requirement for hospitalizations, amputations, and loss of an eye became enforceable on January 1, 2016, following enactment of Public Act 199 of 2015, which aligned Michigan's rules with federal OSHA changes effective January 1, 2015.
Source: MIOSHA Part 11, Recording and Reporting of Occupational Injuries and Illnesses (Administrative Rules) | MIOSHA Recordkeeping and Reporting