What and When are Companies Required to Report or Record for OSHA
In general, companies are required to report or record injuries and illnesses that occur in the workplace. However, there are specific cases where this requirement may differ - for example, if an injury results in hospitalization within 24 hours of the work-related incident, then it must be reported to OSHA directly within 24 hours. In addition, any hospitalizations due to work-related COVID-19 cases must be reported within 24 hours of exposure to the virus.
For non-severe injuries and illnesses, companies are required to maintain records of these incidents in accordance with OSHA's Recordkeeping Rule. These records must be made available to OSHA upon request, and companies must also submit an annual summary of these injuries and illnesses to OSHA
Workplace fatalities and COVID-19 deaths must be reported to OSHA within a certain timeframe, while all recordable injuries or illnesses need to go on the Form 300 Log. Companies must ensure they are taking the necessary steps to protect their employees and report any incidents that do occur.
COVID-19 fatalities are no exception: if a worker dies within 30 days of being exposed to the virus, under the new guidance released in October 2020, you must report the death to OSHA.
How Do You Know if a Case is Recordable?
Not every illness or injury needs to go on the OSHA Form 300 Log and in general, you only need to report or record an illness or injury if it involves:
- Fatality
- Occupational hearing loss
- Loss of consciousness
- Days off work
- Restricted work, transfer
- Medical treatment
So, if an injury requires an employee to seek medical attention other than basic first aid or go on restricted or modified duty, then it needs to be entered on the OSHA 300 Log. However, you don't need to record cases requiring only first aid (or that don’t include elements from the list above).
What Constitutes First Aid?
If you get injured at work, your company is required to provide first aid according to OSHA standards. First aid can include a one-time treatment and usually doesn't require any special technology or training. The requirements for when and how companies must report, or record injuries vary depending on the severity of the incident.
If you get a minor wound at work, such as a cut or scrape, it usually doesn't need to be reported to OSHA. However, if the injury requires treatment or is more serious in nature, then it must be recorded and reported.
For an injury or illness to be considered recordable by OSHA, it must require medical treatment, time off work, and/or restricted work or transfer. In addition, the injury or illness needs to be work-related according to OSHA's broad definition.
Work-relatedness is determined by whether an event or exposure in the work environment caused or contributed to the resulting condition, or significantly aggravated a pre-existing injury or illness, according to Standard Number 1904.5.
Work-related injuries and illnesses can come from many different places, both on and off the job site. It's important for companies to understand what constitutes a work-related injury or illness to report them properly to OSHA. For example, an employee who may have a hernia has the condition aggravated by his work. In that case, you need to record the hernia, even though it didn't originate from the workplace.
Exceptions listed in Standard 1904.5(b)
If you get injured or ill at work, there are some things that your company is required to report to OSHA, and other things that they're only required to record. If the injury happened because of something non-work related, then it doesn't need to be reported. But if the injury was caused by something at work, then your company needs to report it.
When companies are required to report or record for OSHA depends on the situation. If an employee is injured while they are not working, but still on company property, then it must be reported. However, if the injury occurred outside of work and was unrelated to anything at the workplace, then it does not need to be recorded.
- If the injury happened thanks to the employee’s voluntary participation in a wellness program (like a fitness exam, recreation activity, or a flu shot)
- If the illness is the result of the employee eating or drinking something they brought in or ordered
- If the injury occurs when the employee is completing personal tasks during work hours at the establishment
- If the injury is self-inflicted (intentionally)
- If the illness is the common cold or influenza
- If the illness is mental illness (unless a licensed health care professional deems otherwise, e.g., PTSD derived from work)
- If the injury occurs on the access road or in the parking lot during the employee’s commute to or from work
What is a “serious” injury or illness?
Serious injuries and illnesses are ones that result in death, days away from work, restricted work, or transfer to another job. If an employee is injured at work and it requires the employee to take time away from their usual duties, or if they must be transferred to a different job, then it is considered a days-away-from-work case.
A days-away-from-work injury is one where the employee was unable to perform at least one day of their regular work duties because of the injury or illness. This could be due to recuperation from the injury, seeking medical treatment, etc.
If an employee is injured at work and they are unable to perform their regular job duties, but they are still able to perform some other type of work (modified duty), then it is considered a restricted-work case.