Checking OSHA sources after an AI-drafted incident summary
The output may look thorough: it can identify a possible cause, list corrective actions, and summarize an incident. It does not determine whether an incident meets a reporting or recordkeeping threshold, or which obligations apply in a particular state.
That silence is a problem — because in the US, some workplace incidents carry specific documentation obligations, and not knowing about them doesn't change whether they apply to you.
This article is part of the series Why a Chat Window Isn't an Investigation.
What OSHA Requires — and What to Check
The Occupational Safety and Health Administration (OSHA) sets federal workplace safety standards across most US industries. For workplace incidents, two OSHA obligations are relevant to many small businesses.
OSHA recordkeeping — Most employers with more than ten employees are required to record certain types of workplace injuries and illnesses on OSHA Form 300 (the Log of Work-Related Injuries and Illnesses). A lost-time injury — one where an employee misses work — is typically a recordable event. The record must be maintained and is subject to inspection.
OSHA reporting — Certain severe incidents — fatalities, in-patient hospitalisations, amputations, or loss of an eye — must be reported to OSHA directly, within defined timeframes (24 hours for hospitalisations, 8 hours for fatalities).
These are federal minimums. State-level plans (such as California's Cal/OSHA or Washington's L&I) may have additional or different requirements.
A general AI tool does not determine OSHA recordability criteria or legal obligations for a specific incident and jurisdiction. Use current OSHA guidance and qualified advice to identify what applies.
Using a Structured Review Process
A structured investigation workflow can help organize the facts, evidence, and questions that a responsible person should review. The state where a business operates, the incident type, and the severity of the outcome can affect applicable requirements.
It does not replace legal advice or make compliance determinations. Use the facts of the incident, current official guidance, and qualified advice to decide which requirements to investigate.
The Worked Example: A Lost-Time Injury With No Regulatory Context
A warehouse worker slips on spilled oil near a loading dock in a small manufacturing business and loses time from work. The owner describes the incident to a general AI tool and receives a summary: cause identified, corrective actions listed, narrative produced. The response makes no mention of OSHA. It does not flag that a lost-time injury is typically an OSHA-recordable event. It does not note that OSHA Form 300 may need to be updated. It does not identify the jurisdiction or flag whether any state-specific obligations apply.
The owner files the chat output and moves on. Six months later, during a routine OSHA inspection, the inspector asks to see the Form 300 log. The entry for this incident isn't there — because no one flagged that it needed to be.
A responsible person should use current official guidance and qualified advice to review the recordkeeping context before deciding what action is required.
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The Difference Between Awareness and Compliance
No product can determine whether you are legally compliant or file reports on your behalf. MyInvestigationCoach supports a human-led investigation workflow and draft review; use current official guidance and qualified advice to assess applicable requirements.
A general AI tool skips this entirely. It is not built for a specific jurisdiction, a specific industry, or a specific regulatory regime. It responds helpfully in general terms. For most questions, that is fine. For a workplace incident investigation in the US, the regulatory context is not optional background — it is part of the investigation.
As discussed in the series overview, this is one of four gaps between a general AI tool's output and a complete investigation. The others — evidence collection, root cause analysis depth, and completeness checking — each compound this one.
If a review identifies a gap, use the available evidence, current official guidance, and qualified advice to decide what to investigate before finalizing a draft.