Recordkeeping is required by OSHA. There are three forms that must prepared and, in most cases, sent to OSHA: forms 300, 300A, and 301. This article will consider each of these forms in turn, including their purpose, the requisite information, and the process of submitting the forms to OSHA.
Keeping records is an essential safety practice. Records help employers understand trends and monitor the effectiveness of their safety programs. When used as part of a complete safety program, recordkeeping is more than simply recording events. By keeping track of injuries and incidents, recordkeeping can identify problems and help prevent future injuries.
WHAT INCIDENTS MUST BE RECORDED?
It is important to have a strong understanding of what events constitute recordable injuries and illnesses under OSHA’s standard 29 CFR 1904. For an injury or illness to be recordable, the following questions must be answered affirmatively:
- Did the employee experience an illness or injury?
- Is it a new case?
An injury or illness constitutes a new case if it occurs to an employee with no previously recorded injuries, or no previously reported injuries to the part of the body that is currently affected.
Injuries must also be designated as a new case if an employee receives an injury to the same body art as a previous injury that has completely healed.
- Is the case work-related?
A work-related case is defined as a case in which an exposure or event in the workplace caused or contributed to an injury or illness. The work environment includes all locations where employees are working or are present as a condition of employment. Tools and work-related materials are also considered part of the work environment.
OSHA names nine exceptions, in which an injury or illness occurs in the workplace and is not recordable. The nine exceptions are:
- 1.The employee was present in the work environment as a member of the general public at the time of the exposure. This includes injuries that occur after-hours or at social events.
- 2.The signs and symptoms of an illness become evident at work but are solely the effects of events or exposures that occurred outside of work.
- 3.The injury results from voluntary participation in wellness program or activity, such as exercise classes.
- 4.The injury or illness results from food or drink prepared for personal consumption. Note: if food supplied by the employer is contaminated or results in food poisoning, it is a work-related injury.
- 5.The injury occurs while an employee is doing personal tasks unrelated to their job, outside of working hours.
- 6.The injury is intentionally self-inflicted or is the result of personal grooming.
- 7.The injury is the result of a motor vehicle accident that occurs on a company access road or parking lot while the employee is commuting to or from work.
- 8.The injury is the common cold or flu.
- 9.The injury is the result of mental illness. Note: A mental illness can be considered work related if an employee voluntarily supplies an opinion from a doctor or other licensed healthcare professional that states a mental illness is work-related.
- Does the case fit the recording criteria?
OSHA defines a recordable injury or illness as:
- Any work-related fatality.
- Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
- Any work-related injury or illness requiring medical treatment beyond first aid.
- Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
- There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.
OSHA form 300, Log of Work Related Injuries and Illnesses, often referred to simply as the “OSHA log,” collects and classifies information about work-related injuries and illnesses. For each work-related injury or illness, form 300 must record the injured employee’s identification and job title, the incident date, a description of the injury (including the affected body part and the object that caused the injury), the location of the part of the worksite in which in the injury occurred, and the severity of each case. The severity of each case falls into one of four categories:
- Days away from work
- Job transfer or restriction
- All other recordable cases
Finally, you must enter the number of days the injured or ill worker missed work entirely or was on restricted work activity. This section includes all calendar days, whether the employee was scheduled to work that day or not. The total missed time recorded cannot exceed 180 days. If at any point new or better information becomes available, the log can be changed. If a change must be made, you can cross out or white out incorrect information; you do not need to start a new form.
Form 301 is the Injury and Illness Report. Form 301 is for each individual case, unlike form 300, which is a log of all injury or illness cases. Both forms must be updated as incidents occur. Form 301 must be filled out by a maximum of 7 days after an injury or illness. You can fill out this form by summarizing what you entered on form 300. If this information is already filled out on insurance forms or other forms, you do not need to fill out form 301. However, it is important to make sure all the information required by form 301 is contained in alternative reports.
Form 300A is the Summary of Work-Related Injuries and Illnesses. The purpose of this form is to summarize all injury and illness incidents by transferring the totals from form 300. All incidents listed on form 300 must be counted and listed as a total on form 300A, even if the total is zero. The form must contain the signature of a company official verifying all the information on the form has been reviewed and is correct. The company official must be owner of the company, an officer of the corporation, the highest-ranking company official at the establishment, or that person's supervisor.
In order for record keeping to achieve its intended purpose, namely, identifying the scope of injuries and illnesses at a workplace so that preventive measures can be taken, employees need to be involved in the process. This includes being trained to accurately report all injuries and illnesses, no matter how slight. Workers must also be assured of their right to report any illness without fear of retaliation or negative consequence. OSHA’s recordkeeping standard contains provisions that encourage employees to report all relevant information. Employers are forbidden from retaliating against employees who report information to OSHA, whether through firing, demotion, or some other means. Employees must be informed that they have this protection. OSHA “It’s the Law” worker’s protection posters should be posted throughout your facility, to make sure workers are aware of their rights.
SUBMITTING RECORD-KEEPING DATA
The amount of data that must be submitted to OSHA is dependent upon:
- 1.the size of the company
- 2.the type of industry:
- If a business has 250 or more employees in an industry covered by the recordkeeping regulation, information from forms 300, 300A, and 301 must be electronically submitted.
- If a business has 20-249 employees and operate in an industry with historically high rates of occupational injuries and illnesses, information from form 300A must be electronically submitted. The complete list of higher-risk industries can be found on OSHA’s website:(https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.pdf)
- If a business maintains fewer than 20 employees throughout the year, they do not have to routinely submit information electronically to OSHA, unless OSHA makes a written request for data.
Data for injuries and illnesses that occurred in 2017 must be submitted to OSHA by July 1, 2018. Beginning in 2019, data from the previous year must be submitted to OSHA by March 2nd of the current year.
KEEPING AND STORING RECORDS
The records must be kept for 5 years and posted in a visible location from February 1st to April 30th following the year covered by the summary. Any employee or employee representative also has the right to limited access of injury and illness records in a timely manner. This information must be provided to the employee or employee representative by the end of the next business day following the request.
Recordkeeping is an integral part of any workplace safety program. Diligent recordkeeping allows employers to identify potential problem areas and implement necessary safety changes. For more information on OSHA’s recordkeeping standard, visit: https://www.osha.gov/recordkeeping/.