OSHA Recordkeeping and Reporting

Under Occupational Safety and Health Administration (OSHA) standard Part 1904, all covered employers are required to record and report any work-related fatalities, injuries and illnesses of their covered employees using the OSHA Forms 300, 300A and 301.

  • Employers who are required to keep Form 300 (the Injury and Illness log) must post Form 300A (Summary of Work-Related Injuries and Illnesses) in the workplace every year from February 1 to April 30
  • All covered employers must report to OSHA any workplace accident that results in fatalities or multiple inpatient hospitalization within eight hours

Complying with reporting or recordkeeping required by OSHA Part 1904 does not mean that:

  • either employer or employee was at fault or
  • an OSHA rule was violated or
  • the employee is eligible for worker's compensation or other employee accident benefits

Explained below are the key OSHA requirements for recordkeeping and reporting:

OSHA Reporting and Recordkeeping Forms

There are three key forms for recording injuries and illnesses:

OSHA Recordkeeping Criteria

The following are the general criteria for recording an event:

  • Death
  • Days away from work
  • Restricted work activity or transfer to a new or different job due to injury/illness
  • Medical treatment beyond first aid
  • Loss of consciousness
  • Significant injury/illness diagnosed by physician or licensed health care provider.

OSHA has specified additional criteria for recording an event.

OSHA Record Retention and Updating

OSHA 300 Log , the privacy case list (if one exists), OSHA 300A , and the OSHA 301 Incident Report forms must be retained for five years following the end of the calendar year that these records cover. OSHA 300 Logs must be updated to include newly discovered recordable injuries or illnesses and to show any changes that have occurred in the classification of previously recorded injuries and illnesses. There is no need to update OSHA 300A and OSHA 301 forms.

Annual Summary

Employers have to create an annual summary based on injuries and illnesses recorded on the OSHA 300 Log. It must be reviewed and certified by a company executive, i.e. owner, partner, highest ranking official at location. The annual summary must be:

  • posted for 3 months from Feb 1-April 30 following the year covered
  • posted in a place where employees can see it

Covered Employers

The following employers have to comply with OSHA's recordkeeping and recording requirements:

  • Employers with more than ten employees whose establishments are not classified as a partially exempt industry must record work related injuries or illness using the OSHA forms 300, 300A and 301
  • All industries in agriculture, construction, manufacturing, transportation, utilities and Wholesale trade sectors

Self-employed individuals are not covered by the OSH Act or this regulation. The regulations also specify which employers are partially exempt from complying.

Covered Employees

All employees on payroll are covered under the OSHA recordkeeping and reporting requirements whether they are labor, executive, hourly, salary, part-time, seasonal, or migrant workers. OSHA also specifies how and when temporary employees are covered under the law.

Work Related Injuries and Illnesses

OSHA has very specific definition for what it means by work-relatedness . Work-related injuries as defined by OSHA have to be recorded in the OSHA 300 Log . The same applies to work-related illnesses as well.

Reporting Fatalities and Multiple Hospitalization Incidents

According to 29 CFR 1904.39, all employers covered under OSH Act must orally report to OSHA within eight hours of:

  • The death of an employee due to a work related incident
  • The in-patient hospitalization of three or more employees as a result of a work-related incident

OSHA has detailed the ways in which the incidents can be reported and the reporting requirements as well

Privacy Issues

To protect the privacy of injured and ill employees, an employer may not record the employee's name on the OSHA 300 Log for certain "privacy concern cases". Instead of writing name he/she must enter "privacy case" in the space provided.

OSHA has specified what injury or illness is considered a privacy concern case .

ComplianceOnline Training on OSHA Standards
Fundamentals of OSHA Injury and Illness Recordkeeping with Key Interpretations
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