OSHA Workplace Injuries and Illnesses Recordkeeping Requirements – Here’s the Scoop

OSHA RULES REGARDING THE REPORTING OF FATALITIES AND SEVERE INJURIES by Safety Counselling 505-881-1112

OSHA mandates that enterprises in various industries, including construction and manufacturing, fill out documentation about workplace safety and update it consistently. The OSHA 300 log, which is used to record the specifics of illnesses and injuries that occur at your job, is the most well-known. It is essential to keep up with the latest information and correctly fill out the forms, even though it may seem like more paperwork. It is possible to incur hefty penalties and cause damage to your whole compliance program if you fail to submit the paperwork on time and get it right. These are only the recordkeeping infractions that OSHA inspectors detect, and they do not include any workplace safety violations that they find. OSHA inspectors are not bashful about handing out citations.

What Do the OSHA Recordkeeping Forms for Injuries and Illnesses Look Like?

Your organization must retain the records specified by OSHA, including the OSHA 300, OSHA 300a, and OSHA 301 forms. The OSHA Form 300 is the official record that must be used to track the specifics of any injuries or illnesses that occur while employees are on the job. It is divided into three primary parts, namely:

  • Recognizing the nature of the injury or sickness (name, case number, job title)
  • It provides a description of the injury (including the date of the event, the location where it took place, and a description of the damage or sickness).
  • Using the checkboxes, we will categorize the injury according to the consequence of the damage (for example, lost work or hospitalization) and the general type of injury or disease.

When you note the illness or injury on log 300, you must also fill out Form 301 simultaneously. Form 301 is the Injury and Sickness Incident Report for each occurrence, and it offers you additional opportunity to explain the injury or illness as it occurred in context. This report is required after each incident that results in an injury or disease.

The 301 report is where you will describe the account of what took place, why it took place, and the consequences it had for the employee. At the end of the year, you must finish filling out Form 300A, your report summarizing the log. Form 300 is used in the completion of Form 300A by identifying, among other things:

  • The total amount of fatalities
  • The total number of instances that required time off from work
  • The total number of instances involving work restrictions or transfers
  • Total number of additional cases that can be recorded
  • The total number of workdays missed by the employee
  • The total number of days spent in new employment or under restrictions
  • The total number of cases of skin problems, respiratory ailments, hearing loss, poisoning, and any other illnesses that have been reported.

This form only keeps a count of the effects of diseases and injuries that occurred at your organization. It does not contain any personally identifiable information on the staff members.

What Adjustments Have Been Made to the Prerequisites by OSHA?

When OSHA unveiled Forms 300, 300A, and 301 in 2002, it was the first significant reform to the agency’s recordkeeping procedures. A need to record needlestick and sharps injuries, musculoskeletal diseases, TB transmission, and cases of standard threshold shift (STS) hearing loss was included in the modifications released in 2002. The next significant revision was made by OSHA in 2015 when new reporting and recordkeeping requirements were implemented. You are required to report work-related fatalities, hospitalizations, and losses of an eye within a specific time limit beginning in 2015. You may do this by contacting the OSHA toll-free number at 1-800-321-OSHA or by calling the most convenient regional office.

The significant modification to recordkeeping procedures that OSHA implemented in 2015 mirrored the list of partially exempt industries, which we will discuss in the following paragraphs. In addition, it expanded the list of businesses that are required to keep records by including new businesses such as stores selling automotive parts, accessories, and tires; commercial and industrial machinery and equipment rental and leasing businesses; and stores selling building materials and supplies. Employers with more than ten workers must keep OSHA Forms 300, 300A, and 301, and they have until February 1 to display Form 300A in the workplace. The exception to this rule is businesses operating in low-risk sectors. Form 300A must be submitted to OSHA by many firms that have more than 20 employees by the due date of March 2.

The most recent revision, titled “Improved Tracking of Workplace Injuries and Illnesses,” was issued by OSHA in 2016 and published as a regulation. The fundamental standards of recordkeeping were not altered in any way. The most significant modification was introducing a new requirement that businesses in covered industries with more than 250 employees submit all three forms annually to OSHA. OSHA released a “final rule” in January 2019 that abolished the obligation to file Form 300 and Form 301 yearly. This change took effect immediately. Nevertheless, logging and posting requirements must still be met by companies with more than ten workers who are not included on the list of industries exempt from these rules. They are required to keep Forms 300, 300A, and 301 up to date annually.

They have until April 30 to keep Form 300A placed at the workplace after it was initially posted on February 1.  In addition, businesses that have more than 20 workers are required by OSHA to submit Form 300A by March 2 using their Injury Tracking Application. This is the case for many kinds of businesses. Requirements for Keeping Records Under COVID-19 of OSHA

Organizations that are required to comply with OSHA requirements face several issues that are unique because of COVID-19. Because OSHA often revises the standards for COVID-19, it is essential to check in regularly to ensure that your OSHA 300 record has all that it should include.

When a case is work-related and fulfills the recording criteria in 29 CFR 1904.7, OSHA will require businesses to record all COVID-19 cases beginning in November 2020. The standard for recording a patient may be found in that regulation. This demonstrates that COVID-19 is distinct from the influenza virus, as you are not required to report instances of influenza, even if the virus has spread throughout the workplace.

In other words, you will document only some incidence of COVID-19 that occurs at your place of employment. However, you are required to examine each incident to determine whether it is linked to work and to record it on the OSHA 300 log whenever there is evidence that the incident is related to work. OSHA will judge you based on how reasonable your inquiry was and the evidence that was available to you. And because most verified COVID-19 instances will result in days missed from work, the OSHA 300 log should include most job-related cases. You may see the memorandum on enforcement guidelines for COVID-19 records here and the page that OSHA has devoted specifically to COVID-19 here.

Why Does OSHA Have Such Strict Requirements Regarding Recordkeeping?

The standards of OSHA recordkeeping are not intended to embarrass employers or draw attention to employees’ injuries on the job. The purpose of these stringent regulations is to keep a record of illnesses and injuries to learn better how to protect employees in the future. Keeping track of these helps you (and OSHA) detect patterns and address potentially harmful or hazardous issues in the workplace. These will also assist you in locating potential hazards, allowing you to do so before either additional employees have injuries, or an OSHA inspector does so on their own and issues a monetary penalty.

Who Is Required to Accomplish the Recordkeeping Requirements Set by OSHA?

An OSHA Form 300 must be filled out by virtually any employer with more than ten staff members. The only exemption to this rule is if the industry in which your company operates is one of those identified in the regulation update from 2015. Certain businesses that OSHA considers “low-risk” were included on the updated list in 2015; these industries are only partially free from OSHA regulations.

Where exactly do you post your logs, and how often do you do so?

If OSHA mandates that you fill up OSHA Form 300 logs, you are responsible for ensuring that these logs are always up to date. It would help if you weren’t filling them out on a monthly, quarterly, or even worse—a year.  You are required to publish a summary of the forms from the previous year between February and April of the following year. For instance, you will post your resume in 2021 between February and April 2022. Even though you only must keep them up for a few months, you must retain all of the records at the job site for at least five years.

Please tell me about the OSHA Final Rule.

In the past, OSHA required businesses with 250 or more employees to submit their Forms 300 and 301 electronically. On the other hand, you can continue doing this. The administration rescinded the requirement that paperwork is submitted digitally in a document called the “OSHA Final Rule.” Because Form 301 contains personal information about your employees, such as their name, date of birth, and medical treatment, OSHA decided to repeal the regulation that required electronic submission to safeguard the workers’ right to privacy.

However, the only component of the statute repealed was electronic filing. There is no way to get out of the obligation to preserve, post, and maintain your OSHA 300, 301, or 300A form for inspection purposes. In addition, each of these businesses must submit a Form 300A report yearly through OSHA’s Injury Tracking Application using an electronic filing system. Making Use of Electronic Documents to Satisfy OSHA Requirements. Even though OSHA will no longer require you to utilize electronic filing for Forms 300 and 301, this does not indicate that you should switch back to paper filing or use a spreadsheet instead. In addition, the way you maintain track of your Form 300 records impacts how quickly, accurately, and ultimately you can complete and submit your Form 300A each year.

What Kind of Penalties Does OSHA Have in Place for Those Who Fail to Keep an OSHA 300 Log?

In January 2022, there was another rise in the number of OSHA infractions. Infractions related to recordkeeping can result in fines of up to $14 502 dollars. If you are found to violate the standards during an OSHA inspection of your facility, you will be subject to a fine of $14,502 regardless of whether you have displayed your Form 300A, which is a report of your log.

Are You Staying Compliant with the OSHA Recordkeeping Requirements?

Your requirements to keep records for OSHA ensure that your company follows federal rules and protect your employees from being sick or hurt in ways that could have been avoided. The OSHA forms 300, 300a, and 301 give an exhaustive inventory of the reportable injuries and illnesses at your job, subject to OSHA regulations. You must finish these forms promptly if your industry needs to be added to the list of those partially exempt from this regulation. Also, remember that you are required to report any hospitalizations or fatalities directly to OSHA.

Ensure that a Digital OSHA Log is Kept

The use of digital recordkeeping allows businesses to reduce their reliance on paper documents while simultaneously ensuring that all their compliance requirements are met. Several companies provide high-quality safety management systems that are also user-friendly, making it easy to comply with your recordkeeping obligations. Ensure that your OSHA 300 Log and your list of injuries that have been recorded are in sync. You may save it on your computer, print it off, and put it to use to finish preparing Form 300A for display between February 1 and April 30 of each year.