Scope and Coverage

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Scope and Coverage

Reference Number: MTAS-1493
Reviewed Date: 09/04/2026

Tennessee cities are subject to the injury and illness recordkeeping and reporting requirements of the Tennessee Occupational Safety and Health Act (TOSHA). Although some private employers may qualify for partial exemptions from routine injury and illness recordkeeping based on employer size or industry classification, those exemptions do not apply to public-sector employers.

Accordingly, a city must maintain occupational safety and health injury and illness records in accordance with Tennessee Department of Labor and Workforce Development Rules Chapter 0800-01-03, Occupational Safety and Health Record-Keeping and Reporting. This generally includes the OSHA/TOSHA 300 Log of Work-Related Injuries and Illnesses, the 300A Summary of Work-Related Injuries and Illnesses, and the 301 Injury and Illness Incident Report, as applicable.

The city must record work-related fatalities, injuries, and illnesses that meet the applicable recording criteria. Recording a case does not, by itself, establish that the city or employee was at fault, that a TOSHA standard was violated, or that the employee is eligible for workers’ compensation or other benefits.

Local Compliance Programs
A local government that previously elected to operate its own self-compliance safety and health program under T.C.A. § 50-3-910 must include recordkeeping provisions in its written program that are at least as effective as T.C.A. § 50-3-701 and comply with TOSHA Rules Chapter 0800-01-03.

Covered Employees
For recordkeeping purposes, the city must record qualifying work-related injuries and illnesses for all employees on its payroll, regardless of job title, pay status, or work schedule. This includes laborers, executives, hourly and salaried employees, part-time employees, seasonal employees, and migrant workers.

The city must also record qualifying work-related injuries and illnesses involving temporary, leased, contract, or other non-payroll workers when the city provides their day-to-day supervision. Day-to-day supervision means the city directs not only the expected work result but also the details, methods, means, and processes used to perform the work.

When a temporary help agency, employee-leasing company, contractor, or other outside employer provides the worker’s day-to-day supervision, that outside employer is generally responsible for recording the injury or illness. The city and the other employer should coordinate so that each injury or illness is recorded only once. Self-employed individuals, including sole proprietors and partners, are not employees for OSHA/TOSHA recordkeeping purposes.

Recordability Standard
A city must record a work-related injury or illness when it results in one or more of the following:

  • Death.
  • Days away from work.
  • Restricted work or a job transfer.
  • Medical treatment beyond first aid.
  • Loss of consciousness.
  • A significant injury or illness diagnosed by a physician or other licensed health-care professional.
  • Another condition specifically designated as recordable under applicable OSHA/TOSHA rules.

Workers’ compensation reporting and TOSHA recordkeeping are separate requirements. A workers’ compensation claim is not automatically recordable on the TOSHA log, and a recordable TOSHA case may not necessarily result in a compensable workers’ compensation claim.


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