Recordkeeping is an important part of any safety professional’s job, and when it comes to OSHA reporting, there are many details to remember and requirements to address.
In a webinar called “OSHA Reporting and You," Zach Pucillo, CSP, CHMM, EHS compliance manager at KPA, explained the details of OSHA recordable or reportable incidents and the recordkeeping they require.
Understanding these requirements can help you feel confident as you prepare your annual OSHA reports.
Who Needs to Comply?
Most organizations must comply with OSHA’s recordkeeping regulations in full, but there are exemptions and partial exemptions, as well as additional rules based on size, industry type and geography.
- Size: Small employers, defined as having 10 or fewer employees at all times throughout the work year, are exempt from filing. However, it is still considered a best practice to keep these records.
- Geography: OSHA has regional local emphasis programs that might add reporting requirements for your organization. To see the full list, visit OSHA’s Directives - Regional LEP page.
Defining OSHA Recordable or Reportable Injuries and Illnesses
When an injury or illness occurs, a safety professional must determine 1) if the incident is recordable and then 2) if it is reportable.
Step 1: Is the Illness or Injury Work-Related?
While this requirement is fairly straightforward — for example, an employee on the shop floor gets dirt or debris in their eye — it can get complicated, like when a car crash occurs in the company parking lot. Generally speaking, if the incident occurs while performing work on work property, it is likely work-related. However, OSHA has defined several notable exceptions that include these situations:
- Occurs to the general public
- Certain parking lot incidents
- Non-work-induced mental illness
- Colds or flu
- Injuries that arise from personal meals or grooming
- Injuries that are self-inflicted or self-medicated
- Injuries that occur on work premises but are due to natural disaster
Step 2: Does the Injury/Illness Require Medical Attention Beyond First Aid?
Work-related injuries or illnesses that require medical attention beyond first aid are recordable. Consider the example of an employee getting debris in their eye. The physician on site uses eye flush solution and does not administer pain medication. The employee is sent home for the rest of the day. This is not a recordable incident because irrigating the eye is considered first aid.
However, if the debris caused a scratch on the worker’s eye and they receive a medicated drop to administer on a daily basis, that goes beyond first aid and, therefore, is a recordable incident.
This can be nuanced, which is why OSHA clearly defines first aid in 29 CFR 1904.7(b)(5)(ii).
Step 3: Is the Recordable Incident Reportable?
A recordable incident becomes a reportable incident when it meets two specific criteria: 1) it causes a fatality, or 2) it causes injuries that require in-patient hospitalization or that result in amputation or loss of an eye.
For reportable incidents, it’s important to know these OSHA mandates:
- A fatality must be reported to OSHA within eight hours.
- An in-patient hospitalization, amputation or loss of an eye must be reported within 24 hours.
Additionally, a fatality that occurs within 30 days of the incident, or an in-patient hospitalization, amputation or loss of eye that occurs within 24 hours of the work-related incident must be reported.
Step 4: How to Report an Incident
If a reportable incident occurs, you have three options:
Pucillo recommends using the hotline or online reporting form to ensure you meet the time requirements. To that end, it’s also important to make sure you have a process in place to report incidents that occur outside of regular business hours.
Meeting OSHA Recordkeeping Requirements
If your incident is OSHA recordable or reportable, you will need to take swift action to gather information. Here’s what you will need:
- Establishment name
- Location of the work-related incident
- Time of the incident
- Type of reportable event
- Names and number of employees
- Contact person and phone number
- Brief description of the work-related incident
You will use that information to complete one or more of these OSHA forms:
- OSHA 301 form (Injury and Illness Incident Report): This report contains all relevant information about what happened.
- You can use this form or another provided by your employer or insurance carrier as long as it requires equivalent information to the 301 form.
- You must fill this out within seven calendar days of notification of work-related injury or illness and keep it for five years.
- OSHA 300 form (Log of Work-Related Injuries and Illnesses): This is maintained throughout the year:
- Whenever you complete a 301 or other incident report form, you must then translate it to the 300 log for recordkeeping.
- This form would be requested by a compliance officer during a site inspection.
- OSHA 300-A (Summary of Work-Related Injuries and Illnesses): At the end of the year, you summarize each column from the OSHA 300 form.
- This shows the year’s work-related injury/illness totals in each category without employee names.
- This form must be signed by a certifying official and posted in a highly visible, high-traffic area in your facility between Feb. 1 and April 30 the following year.
You do not need to mail the forms to OSHA unless specifically requested to do so, Pucillo says. The Bureau of Labor Statistics may randomly request this information for statistical analysis. However, your facility may need to electronically submit recordkeeping data to OSHA if you have more than 250 employees or if you have 20 to 249 employees in certain high-risk industries.
Currently, there is an amendment to the injury and illness recordkeeping regulation which is in the final stages of the rulemaking process. This amendment was moved to the final rule stages in 2022. The Federal Register states:
“OSHA proposes to amend its regulation to require establishments with 100 or more employees in certain designated industries to electronically submit information from their OSHA Forms 300, 301, and 300A to OSHA once a year.
Establishments with 20 or more employees in certain industries would continue to be required to electronically submit information from their OSHA Form 300A annual summary to OSHA once a year. OSHA also proposes to update the classification system used to determine the list of industries covered by the electronic submission requirement. In addition, the proposed rule would remove the current requirement for establishments with 250 or more employees, not in a designated industry, to electronically submit information from their Form 300A to OSHA on an annual basis.”
The Importance of Recordkeeping
Finally, while recordkeeping is required for compliance, it can also help you identify injury/illness trends and uncover unaddressed hazards and other safety issues.
“Keeping track of work-related injuries helps prevent them from happening in the future, which is the ultimate goal. We don’t want anybody to get hurt,” Pucillo says.
Pucillo addressed several complex situations during the FAQ section of the webinar (beginning at 27:45).
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