Does OSHA have any specific time intervals when an accident must be reported to an employer, so they employer can properly assess for recordkeeping purposes?

OSHA did not create a time limit for employees to report injuries. Obviously, the sooner an injury gets reported, the easier it is for a company to investigate and determine work-relatedness. However, OSHA has not imposed a time limit for a number of reasons. Among them, some illnesses develop over months or years. Also, if a work-related incident occurred, OSHA did not want a cut-off like “if the employee does not report within 12 months, it’s no longer deemed work-related.” No matter how long an employee delays, the case would still be work-related if it meets the criteria.

Finally, for OSHA to impose any time limit could require that the agency have authority over employees (not just employers). Basically, OSHA could either try to require employees to report within a certain time (which they don’t have authority to do) or they could allow employers to ignore cases that weren’t reported within a certain time (which they don’t want to do for various reasons).

Therefore, even a multi-year delay in reporting or seeking medical attention from a personal healthcare provider do not impact an employer’s obligations to record any work-related cases. That’s not to say that OSHA failed to address the matter entirely. There are two relevant regulations on this.

First, employers must enter recordable cases on the 300 Log within seven days of learning about the case (and the employer might not learn about a case for months or even years). See: 1904.29(b)(3) How quickly must each injury or illness be recorded? You must enter each recordable injury or illness on the OSHA 300 Log and 301 Incident Report within seven (7) calendar days of receiving information that a recordable injury or illness has occurred.

Second, OSHA does require employers to establish procedures for employees to report injuries. See 1904.35(a)(1) You must inform each employee of how the employee is to report a work-related injury or illness to you.

Any unreasonable delays or violations of those procedures are a matter to be worked out between the company and the employee; OSHA doesn’t impose sanctions on employees, so they essentially removed themselves from that process.

In the end, employers have to do the best they can in these situations, using whatever information is available, and potentially making credibility evaluations regarding the employee’s version of events.