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Your Guide to OSHA Recordkeeping and Reporting
Thursday, Apr 8th, 2021
The Occupational Safety and Health Administration, commonly known as OSHA, formed April 28, 1971, under the U.S. Department of Labor “to assure safe and healthy working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.”
Since enforcement is part of OSHA’s mission, they regularly conduct workplace inspections, often following a worker complaint, and during these reviews they may request to see various records of injuries and illnesses.
Because OSHA inspections can result in potentially serious fines, it is wise for all employers to make sure their recordkeeping is thorough and accurate, and aligns with what OSHA would expect to see.
Who is required to keep OSHA records?
Before understanding the types of situations that need to be recorded, it is important to understand if your organization is required to keep OSHA records in the first place.
Under 29 CFR 1904, any employer covered by the Occupational Safety and Health Act with 11 or more employees must maintain OSHA injury and illness records. Employers with 10 or fewer employees and organizations in certain low-hazard industries are partially exempt from keeping such records.
Within many smaller organizations, employee numbers may fluctuate throughout the year. In these instances, employers should review their maximum employment numbers. If at any time during the year, you had more than 10 employees, you are required to record safety incidents, unless you are in an exempt industry.
Additionally, not all employers are covered by federal OSHA regulations. There are currently 26 states and 2 U.S. territories operating under an OSHA-approved State Plan.
While these plans may differ from federal regulations in some aspects, OSHA has been very clear in noting that “State plans must have occupational injury and illness recording and reporting requirements that are substantially identical to the requirements in this part.”
What defines an OSHA-recordable incident?
Simply put, any sort of injury or illness that occurs from a work-related incident and that requires medical treatment, whether from a medical professional or from a layperson, needs to be recorded.
Employers will need to record any incident that results in the following:
- Loss of consciousness
- Days away from work
- Restricted work activity or job transfer
- Hearing loss
- Diagnosed cases of cancer or chronic irreversible diseases
- Needlestick injuries
- Fractured or cracked bones
This may seem extensive, but remember that OSHA does not require every single occurrence to be recorded. If basic first aid is all that is needed to treat an injury, that incident does not need to be noted in OSHA recordkeeping logs.
Also keep in mind any work-related incident that results in a fatality or a severe injury — in-patient hospitalization, amputations or the loss of an eye — must be reported directly, either to the nearest OSHA Area Office, to the 24-hour OSHA hotline or via the online reporting form.
Work-related fatalities must be reported within 8 hours of learning about the death. All other severe injuries listed above must be reported within 24 hours. Unlike any of the recordkeeping restrictions, all employers under OSHA jurisdiction must report these types of incidents; there are no exemptions here.
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What are the OSHA forms I should know?
There are three different OSHA recordkeeping logs that need to be completed and maintained by all applicable organizations. The names of the logs are similar, so they can be easily confused, but here is a simple breakdown of the function of each.
OSHA Form 301
Also known as an Injury and Illness Incident Report form, this contains any injury deemed to OSHA recordable. This form will list the extent and severity of an injury or illness and medical information.
Incidents must be documented within seven calendar days of learning about the injury or illness. This form does not get submitted to OSHA but it must be maintained at your worksite for 5 years.
OSHA 300 Log
The next form is the OSHA 300 Log, which must include incident information such as employee details and if the incident resulted in death, days away from work, a job transfer, or other outcomes.
Similar to Form 301, the 300 Log must also be maintained on the jobsite for 5 years. Employers may need to produce a copy of the 300 Log upon request during an OSHA inspection.
In 2019, OSHA updated the recordkeeping regulation to where applicable organizations now need only submit the OSHA 300A, which serves as an annual summary of all work-related incidents.
Much like the other OSHA forms, this must be kept at the worksite for 5 years. Additionally, the OSHA 300A also needs to be signed by a company executive and displayed in the office from February 1 to April 30 each year.
What needs to be submitted to OSHA?
While the various OSHA logs include detailed information about injuries and illnesses, and these forms must be maintained on-site and may be requested for an inspection, the good news is that the majority of organizations will not need to submit data to OSHA.
As of 2017, the only establishments that must electronically submit 300A are those with 250 or more employees and those with 20 or more employees in certain high-risk industries. In these cases, employers must use OSHA’s Injury Tracking Application portal to submit OSHA 300A data by March 2 for the previous calendar year.
One thing to note is that, for organizations that fall under the above requirements for submitting data to OSHA, an Injury Tracking Application must be completed even if there were no injuries or illnesses. In that case, zeroes would be reported, but this information must still be officially documented.
Are positive COVID-19 cases recordable?
Over the last year, the United States, along with the rest of the world, has seen an ever-growing number of cases of COVID-19, also known as the coronavirus. One question many employers are facing this year is whether to include COVID-19 cases on their OSHA incident forms.
Just over two months after the World Health Organization declared COVID-19 to be a pandemic, OSHA determined that the virus was to count as a recordable illness for all employers.
A case in question is considered OSHA-recordable only if the case:
- Is a confirmed COVID-19 case;
- Is work-related, meaning “resulting from events or exposures occurring in the work environment;” and
- Involves at least one aspect of the general recording criteria (death, days away from work, medical treatment or loss of consciousness)
As mentioned previously, any work-related fatality or hospitalization due to COVID-19 must be reported directly to an OSHA Area Office, to the OSHA hotline or through the online reporting form.
Partner with someone who can help
Ensuring you are doing everything fully by the book and up to OSHA standards can seem daunting, but it doesn’t have to be. Working with an expert in safety training can help you get up to speed and make sure your records are prepared for an inspection or for OSHA submission.
For more than 20 years, SafetySkills has helped thousands of organizations complete safety training on hundreds of topics, including OSHA recordkeeping. Contact SafetySkills today to see how your company can benefit from proven expertise.