The average OSHA recordable incident rate by industry determines whether a subcontractor passes or fails your prequalification screen. In construction, this single metric -- the Total Recordable Incident Rate, or TRIR -- shapes bidding eligibility, insurance premiums, and project access. A sub with a TRIR above your threshold does not get on your jobsite.

This pillar guide breaks down the TRIR formula, 2025 BLS industry benchmarks, what counts as a recordable incident, and how general contractors use these numbers to manage risk across their subcontractor network.

The TRIR Formula: How OSHA Incident Rates Are Calculated

The OSHA incident rate formula is standardized. Every company uses the same calculation regardless of size:

TRIR = (Number of OSHA recordable incidents x 200,000) / Total hours worked

The 200,000 multiplier normalizes the rate to a base of 100 full-time employees working 40 hours per week for 50 weeks. This lets you compare a 15-person electrical subcontractor against a 3,000-person mechanical firm on equal footing.

Example calculation: A concrete subcontractor had 4 recordable incidents last year. Their employees worked a combined 520,000 hours.

TRIR = (4 x 200,000) / 520,000 = 1.54

That 1.54 falls below the construction industry average, meaning this sub would clear most prequalification thresholds.

What Makes an Incident "Recordable" Under OSHA

Not every workplace injury goes on the OSHA 300 log. Recording criteria are defined in 29 CFR 1904 and hinge on the treatment received and the outcome of the injury.

An incident is recordable if it results in any of the following:

Death. Any work-related fatality.
Days away from work. The employee cannot report to work on the day after the injury.
Restricted work or job transfer. The employee cannot perform one or more routine job functions.
Medical treatment beyond first aid. This is the line that causes the most confusion.

First Aid vs. Medical Treatment: The Recording Threshold

The distinction between first aid and medical treatment determines whether an incident hits your TRIR. OSHA defines first aid as a specific, closed list of treatments. Anything not on the list is medical treatment and triggers recording.

Treatment	Classification	Recordable?
Adhesive bandages, butterfly closures	First Aid	No
Non-prescription medications at non-prescription strength	First Aid	No
Tetanus immunization	First Aid	No
Cleaning, flushing, soaking a wound	First Aid	No
Eye patches	First Aid	No
Finger splints	First Aid	No
Stitches or sutures	Medical Treatment	Yes
Prescription medications	Medical Treatment	Yes
Setting a broken bone	Medical Treatment	Yes
Physical therapy beyond first visit	Medical Treatment	Yes
Removal of foreign body from eye by physician	Medical Treatment	Yes
Any surgical procedure	Medical Treatment	Yes

A common mistake: a field supervisor sends a worker to urgent care for a laceration. The doctor applies Steri-Strips (butterfly closures) and prescribes an antibiotic. The butterfly closures alone would be first aid. The prescription makes it recordable. That single prescription adds a recordable incident to the sub's TRIR.

2025 BLS Industry Averages for Construction

The Bureau of Labor Statistics publishes annual incident rates through its Survey of Occupational Injuries and Illnesses. The most recent complete data (2024 survey, published 2025) provides the benchmarks GCs use for prequalification screening.

Industry Sector (NAICS)	Average TRIR	Average DART Rate	Average Hours (millions)
Construction (overall, 23)	2.8	1.6	11,420
Residential building (2361)	3.5	2.1	2,180
Commercial building (2362)	2.8	1.5	3,640
Industrial building (2362-subset)	2.4	1.3	1,290
Heavy and civil engineering (237)	2.2	1.2	2,410
Specialty trade contractors (238)	3.1	1.8	5,790
Electrical contractors (23821)	2.3	1.3	1,450
Plumbing/HVAC contractors (23822)	3.0	1.7	1,680
Structural steel erection (23812)	2.9	1.7	310
Roofing contractors (23816)	4.2	2.5	520
Concrete contractors (23811)	3.4	2.0	680
Painting contractors (23832)	2.6	1.4	440
Excavation contractors (23891)	2.7	1.5	390
Drywall/insulation (23831)	3.3	1.9	470

Heavy/civil work posts the lowest average at 2.2, driven by stringent owner safety requirements on infrastructure projects. Roofing posts the highest at 4.2, reflecting fall exposure inherent to the trade.

How GCs Use TRIR for Subcontractor Prequalification

TRIR is the first safety filter in a prequalification workflow. Before reviewing safety programs, training records, or EMR data, GCs check whether the sub's TRIR falls within acceptable range.

Common TRIR Thresholds by Owner Type

Different project owners set different ceilings. The sub must clear both the owner's threshold and the GC's internal threshold to qualify.

Owner/Project Type	Typical TRIR Threshold	Notes
Federal government (USACE, GSA)	Below 2.0	Often requires 3-year rolling average
State DOT projects	Below 2.5	Varies by state
Pharmaceutical/biotech	Below 1.0	Strictest requirements in construction
Oil and gas (downstream)	Below 1.0	ISNetworld verification required
Data center construction	Below 1.5	Tech owners increasingly strict
Commercial office	Below 2.0	Standard for most institutional GCs
Residential multifamily	Below 3.0	More lenient threshold
Higher education	Below 1.5	University risk management sets limit
Healthcare construction	Below 1.0	Hospital systems require best-in-class

A sub with a TRIR of 2.3 qualifies for residential and state DOT work but gets screened out of pharmaceutical, healthcare, and oil-and-gas projects. That single number can determine 40-60% of available bid opportunities for specialty contractors.

TRIR and the EMR Connection

TRIR and Experience Modification Rate measure different things but reinforce each other in prequalification.

TRIR counts incidents per hours worked. It measures frequency.

EMR compares a company's workers' comp claims costs against the industry average. It measures financial severity. An EMR of 1.0 is average. Below 1.0 means better-than-average claims history. Above 1.0 means worse.

GCs use both because they tell different stories. A sub could have a low TRIR (few incidents) but a high EMR (the incidents that did occur were expensive). Or a sub could have a high TRIR (many small incidents) but a low EMR (minor claims only).

Scenario	TRIR	EMR	What It Means
Best case	Below 1.0	Below 0.80	Few incidents, low severity
Frequent but minor	3.5	0.85	Many small injuries, low cost
Rare but severe	0.8	1.40	Few incidents, but catastrophic when they occur
Worst case	Above 4.0	Above 1.20	Frequent and expensive injuries

Most GCs set thresholds on both metrics. A typical requirement: TRIR below 2.0 AND EMR below 1.0. Failing either one disqualifies the sub.

How TRIR Affects Insurance Premiums

A subcontractor's TRIR directly influences their insurance costs through two pathways.

Workers' compensation premiums. The EMR, which correlates with TRIR, modifies the base workers' comp premium. An EMR of 1.3 means the sub pays 30% more than the base rate. Over a three-year period, a reduction in TRIR from 3.0 to 1.5 can lower EMR from 1.2 to 0.85, saving a mid-size sub $40,000-$120,000 annually in workers' comp premiums.

General liability pricing. Underwriters review TRIR during policy renewals. Subs with TRIR above industry average face premium surcharges of 15-35%. Subs with TRIR consistently below 1.0 receive preferred pricing.

Bid competitiveness. Lower premiums mean lower overhead. Lower overhead means more competitive bids. A sub paying $180,000/year in workers' comp instead of $280,000/year can bid $100,000 lower on the same project without cutting margin.

Annual vs. Rolling 3-Year TRIR

OSHA requires annual recordkeeping on the 300 log. But GCs and owners increasingly demand a 3-year rolling TRIR for prequalification. The rolling average smooths out statistical anomalies.

A 20-person sub that has one recordable incident in a year might show a TRIR of 5.0 for that single year. But averaged over three years with zero incidents in the other two years, their rolling TRIR drops to 1.7.

How to calculate a 3-year rolling TRIR:

3-Year TRIR = (Total recordable incidents in 3 years x 200,000) / (Total hours worked in 3 years)

Do not average the three individual annual TRIRs. That method weights each year equally regardless of hours worked. The correct method pools all incidents and all hours across the full period.

The DART Rate: TRIR's Companion Metric

DART stands for Days Away, Restricted, or Transferred. It uses the same formula as TRIR but only counts incidents that resulted in days away from work, restricted duty, or job transfer. First-aid-plus-prescription cases that are recordable for TRIR purposes do not count toward DART unless they also involve lost time or restriction.

DART Rate = (Number of DART incidents x 200,000) / Total hours worked

DART is always lower than or equal to TRIR. The gap between the two reveals how many of a sub's recordable incidents are relatively minor (recordable but no lost time) versus serious (days away or restricted work).

Sub	TRIR	DART	Gap	Interpretation
Sub A	2.5	0.8	1.7	Most incidents are minor -- medical treatment but no lost time
Sub B	2.5	2.2	0.3	Most incidents are serious -- nearly all involve lost time

Sub A and Sub B have identical TRIRs but very different risk profiles. GCs who only look at TRIR miss this distinction.

Building a TRIR-Based Prequalification System

A structured prequalification system uses TRIR as one component within a broader safety evaluation. Here is how leading GCs structure their approach.

Step 1: Set TRIR thresholds by trade. Do not apply a single number across all trades. Roofing has an industry average of 4.2. Electrical has an average of 2.3. A 2.0 threshold is reasonable for electrical but eliminates nearly every roofer. Set thresholds relative to BLS industry averages for each NAICS code.

Step 2: Require 3-year rolling data. Demand OSHA 300 logs and 300A summaries for the past three completed calendar years plus the current year-to-date. Calculate the rolling TRIR yourself rather than accepting the sub's self-reported number.

Step 3: Verify hours. Cross-reference reported hours against payroll records or certified payroll submissions. Hours inflation is the most common way subs artificially lower their TRIR.

Step 4: Layer additional metrics. Add EMR, DART rate, and fatality history to the evaluation. A sub with zero fatalities and TRIR of 1.8 is a different risk than a sub with one fatality and TRIR of 1.8.

Step 5: Automate collection and calculation. Manual TRIR tracking across 50+ active subs per project creates data entry errors and stale information. A prequalification platform automates the collection, calculation, and threshold comparison.

TRIR Trends in Construction: 2015-2025

Construction safety has improved measurably over the past decade, though progress has slowed in recent years.

Year	Construction TRIR (BLS)	Change from Prior Year
2015	3.5	--
2016	3.2	-8.6%
2017	3.1	-3.1%
2018	3.0	-3.2%
2019	2.8	-6.7%
2020	2.5	-10.7%
2021	2.7	+8.0%
2022	2.8	+3.7%
2023	2.8	0.0%
2024	2.8	0.0%

The 2020 drop reflects reduced construction activity during lockdowns and a shift in the mix of active projects. The plateau at 2.8 since 2022 suggests that traditional safety programs have reached diminishing returns. Further improvement likely requires investment in leading indicators, wearable technology, and predictive analytics.

FAQs

What is the average OSHA recordable incident rate for construction? The overall construction industry average TRIR is 2.8 based on 2024 BLS data. However, this varies significantly by trade. Heavy/civil engineering averages 2.2, commercial building averages 2.8, roofing averages 4.2, and residential building averages 3.5. Always compare a subcontractor's TRIR against the average for their specific NAICS code rather than the overall construction figure.

How often should GCs recalculate subcontractor TRIR? Best practice is quarterly recalculation using a rolling 3-year window. Annual recalculation is the minimum. Many owners now require current year-to-date TRIR in addition to the 3-year rolling average. Quarterly updates catch deteriorating safety performance before it results in a serious incident on your project.

Can a subcontractor with a high TRIR still qualify for projects? Some GCs allow subs with above-threshold TRIR to qualify if they submit a corrective action plan and demonstrate a downward trend. This is called conditional prequalification. It typically includes enhanced site safety monitoring, additional toolbox talks, and a 90-day review period. However, most owners will not accept conditionally prequalified subs on their projects.

What is the difference between TRIR and DART rate? TRIR counts all OSHA recordable incidents including medical treatment beyond first aid, restricted work, lost time, and fatalities. DART only counts incidents involving days away from work, restricted duty, or job transfer. DART is always equal to or lower than TRIR. The gap between the two indicates how many recordable incidents were relatively minor versus serious.

How does TRIR affect a subcontractor's EMR? TRIR and EMR are related but calculated differently. TRIR measures incident frequency per hours worked. EMR compares a company's actual workers' comp claims costs against expected costs for their industry classification. A high TRIR typically leads to more workers' comp claims, which drives EMR above 1.0 over a 3-year lag period. Reducing TRIR is the most direct path to lowering EMR.

Do subcontractors need to include temporary workers in their TRIR calculation? If the subcontractor supervises the temporary worker's day-to-day activities, that worker's hours and any recordable incidents count in the sub's TRIR. If the temp agency maintains supervisory control, the incidents count on the temp agency's log. OSHA issued clarification on this joint-employer question in 2015. GCs should verify how subs handle temp worker recording during prequalification.

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