OSHA Recordkeeping: An Overview of the Rules

Many employers in the United States are obliged to document workplace injuries and illnesses under OSHA’s Recordkeeping Rule. While this document doesn’t need to be submitted to OSHA unless requested, organizations and businesses subject to the recordkeeping rule must produce these documents when requested make them available during inspections. Incident reports and logs of on-site recordable incidents must be maintained for a period of at least five years.

The Occupational Safety and Health Act of 1970 (OSH Act) directs employers who are subject to the rule to annually prepare and maintain a record of occupational injuries and illnesses. This must be reported each year by March 2. Generally, organizations that employ 10 or fewer people during the previous calendar year do not need to report, unless otherwise directed to by OSHA or the U.S. Department of Labor.

Organizations in certain low-hazard industries are likewise exempt from having to report. These include retail trade, finance, insurance, real estate and services industries, or if the three-year average lost-workday case rate for their major industry group was 75 percent less than the overall three-year average of the lost-workday case rate for private industry. Here is a more complete list of exempt industries.

OSHA recordkeeping requirements comprise three forms first introduced in 2002: OSHA 300, OSHA 300a and OSHA 301. OSHA Form 300 is an official log that details every injury or illness that occurs in a workplace and includes three major sections:

• Identifying the injury/illness (name, case number, job title)
• Describing the injury (date of injury, where it occurred, description of injury/illness)
• Classifying the injury using the checkboxes (what was the result of the injury – e.g., missed work, hospitalization – and the general type of injury/illness)

Recording an illness or injury in a Form 300 requires filling out Form 301 at the same time. Form 301 is the Injury and Illness Incident Report for each event and provides additional space to describe the incident in detail, telling the story of what happened, why and what were the effects for the employee.

Data collected and reported by employers must be uniform and accurate, assuring statistical data consistency and validity. OSHA uses recorded data for many purposes, including inspection targeting, performance measurement under the Government Performance and Results Act (GPRA), standards development, resource allocation and Voluntary Protection Program (VPP) eligibility and low-hazard industry exemptions. Recordkeeping data is also used in the analysis of health and safety environments at an employer’s establishment. It is also the information source for the OSHA Data Initiative (ODI) and the Bureau of Labor Statistics’ (BLS) annual survey.

A completed Form 300a, required at the end of the year, tallies the impacts of injuries and illnesses but does not include personal information. Form 300 is used to complete Form 300a by identifying:

• Total number of deaths
• Total number of cases with days away from work
• Total number of cases with job transfer or restriction
• Total number of other recordable cases
• Total number of days away from work
• Total number of days of job transfer or restriction
• Total number of injuries, skin disorders, respiratory conditions, poisonings, hearing losses and other illnesses

In the case of a fatal or serious workplace injury – defined as an amputation, hospitalization or loss of an eye – employers, including those otherwise exempt from OSHA recordkeeping, are required to notify OSHA. A fatality must be reported within eight hours and an in-patient hospitalization, amputation or eye loss must be reported within 24 hours. A report can be made in one of three ways:

• Call the nearest OSHA office
• Call the OSHA 24-hour hotline at 1-800-321-6742 (OSHA)
• Make a report online

Be prepared to supply the business name; names of employees affected; location and time of the incident; a brief description of the incident; and the contact person and phone number.

Finally, forms must be kept on file for five years following the year to which they pertain. It’s also necessary to update the Form 300 with any changes to the recorded cases during that period, although completed copies of the forms should not be sent to OSHA. Forms should be made available to employees, former employees, their representatives and to OSHA officials upon request. Also note that Form 300 and Form 301 incident reports include information relating to employee health and therefore can only be used in a manner that protects confidentiality to the extent possible while promoting occupational safety and health.

For more information about the OSHA Recordkeeping Rule, what needs to be reported and where things often get tricky for many safety professionals, download the Intelex Insight Report: Reporting Injuries and Illnesses: A Guide to OSHA Recordkeeping.

Looking for a management solution for your OSHA Recordkeeping needs? Learn about Intelex Incident Reporting Software and how it makes it easy to capture, track, investigate and manage all incidents and near-misses, including injuries and illnesses, spills, property damage and vehicle incidents.