Understanding the importance of keeping records of incidents in the workplace is absolutely necessary to not only know what hazards are present and waiting to be eliminated, but also to stay in compliance with OSHA regulations.
However, keeping an accurate record of incidents that have occurred is imperative. Accurate record keeping assists the employer in improving company-wide health and safety programs that will in turn assist in preventing future incidents. Emphasizing accuracy in recordkeeping aims to improve employee awareness of hazards, illnesses, and injuries. The goal of increasing employee awareness is to foster a willingness to jump on board with creating a safer workplace.
The OSHA 300 log and the other two sections of paperwork, form 300A and form 301, are documents that no one wishes to fill out for that means someone was seriously injured or killed. Yet, they are necessary learning tools, and required by law, for what needs to be done to improve the workplace with the goal of preventing future incidents from ever occurring.
What is OSHA’s Recordkeeping Rule?
OSHA’s recordkeeping rule establishes the requirement to keep an updated log on serious occupational injuries acquired on the job. The information on an OSHA 300 log, form 300A and from 301, are important for employers, OSHA, and employees because they evaluate the workplace’s overall safety based off the frequency and types of incidents that have occurred. Then, employer and OSHA officials can judge whether or not the safety measures implemented are providing sufficient protection. With that being said, these three documents help the employer and employees better understand the types of hazards within the industry and realize a potential need for new protections or procedures that will aim to mitigate or eliminate hazards entirely.
There are two exceptions to this recordkeeping rule. If an employer has ten or less employees at all times during the year or if they own a business that is classified as a low hazard industry, then they do not have to fill out forms regarding injury or illness to keep on record. Anyone may look to see if their industry fits the exemption criteria by looking to see if the NAICS code assigned to their line of work is within this exempt table.
The recordkeeping rule outlines incidents that require documentation as well as instances that require direct reporting to OSHA. Both instances and their specifications will be covered later in this article.
The Different Types of Recordkeeping Documents
As briefly mentioned before, there are three separate documents that work together in recording accident data. Those forms required by OSHA’s law of recordkeeping are:
- OSHA form 301 – The Injury and Illness Incident Report
- This document contains confidential medical information of the employee who suffered from a reportable injury or illness. It includes the personal information of the employee as well as a list of medical professionals who were consulted about the injury/illness, and incident details. Form 301 must be filled out within seven days of the employer learning of the event.
- OSHA form 300 – The Log of Work-Related Injuries and Illnesses
- Form 300 is essentially the compiled list of injury and illness reports (301 forms) that occurred in the span of a year. Log 300 forms include the worker’s identity, the outcome of the injury or illness, and a description of what happened. Form 300 must be completed even when nothing recordable has occurred.
- OSHA form 300A – The Summary of Work-Related Injuries and Illnesses
- Form 300A is the public summary that takes information from form 300. It does not list the names of the people who suffered from injuries or illnesses, but it does list the days away from work, restricted work, transfers, and the type of injury sustained. The summary must be filled out and posted annually even if no work incidents have occurred
OSHA 300 Log Requirements
There are a few annual and long-term requirements that must be fulfilled for this type of documentation. OSHA requires all three forms – 300, 300A and 301 – to be available on file for five years in case OSHA enforcement personnel requests the forms for an investigation of an accident, injury, or illness. In addition to that, employers are also required to post the 300A summary of incidents from February 1st to April 30th every year. Requiring the 300A forms to be posted allows for a clear and complete mutual understanding between employers and employees regarding the dangers that are present at work.
If the company has more than 250 employees at any point during the year, the employer must also submit form 300A to OSHA electronically by March 2nd annually. This ruling also applies to companies that work in high-risk environments with 20-249 employees.
What is recordable on the OSHA 300 Log?
Not keeping up with recording information on an OSHA 300 log is one of the number one mistakes that employers make. The longer this process is procrastinated on, the harder it will be to fill out in time for an inspection when the records have been asked for. With that being said, injuries or illnesses that result in the following need to be recorded on an OSHA 300 log and must be recorded within seven days of receiving notice that it has occurred:
- Days away from work
- Restricted work or transfer to another job
- Medical treatment that is beyond first aid treatment
- Loss of consciousness
- A significant injury or illness that has been diagnosed by a licensed health care professional
There are instances where privacy is an issue. In those cases, the injury or illness is taken care of confidentially and the employer shall not be allowed to divulge the name of the victim in an OSHA 300 log or publicly available paperwork (300A forms). Those types of injuries and illnesses include:
- An injury or illness acquired relating to the reproductive system or intimate parts of the body
- Sexual assaults
- Mental illness
- HIV infection, hepatitis, or tuberculosis
- Needlestick injuries and cuts from sharps where the objects are contaminated with another person’s blood
What is a reportable OSHA incident?
There are some cases where an employer must alert OSHA of an injury or illness directly due to the severity of the situation. As of January 1st, 2015, new rulings have been put into place where the following instances require an employer to report to OSHA as soon as possible if the injury or illness is work related.
- Hospitalizations of one or more employees
- Eye loss
Every employer, even if the company is exempt from filing incident paperwork, is required to report to OSHA within eight hours when an employee has been killed while working or within 24 hours if an employee suffered a severe injury including an amputation, loss of an eye, or required hospitalization. When reporting these instances, the employer must have the following information on hand for the OSHA official:
- The name of the establishment
- The location of the incident
- The time it occurred
- The type of reportable event it’s classified as
- The number of employees that were involved, their names, and persons of contact
- A brief description of the incident
If these instances happen anywhere other than at the workplace, then OSHA does not need to be contacted.
Updated requirements regarding COVID-19
As the coronavirus continues to spread and make its way into our daily lives at work and at home, those who are essential workers, or have been allowed to return to work, have become concerned about how to deal with this illness in regard to reporting it to OSHA or recording it in any of the three documents mentioned.
For this reason, OSHA has created a memorandum that details how to go about this situation. Coronavirus cases may be recordable on an OSHA 300 form if all the following conditions are met,
- The case has been confirmed to be coronavirus
- The case has been traced to be work-related
- The case involves any or all of the general recording requirements described by 29 CFR 1904.7. These conditions include:
- Days away from work by treatment from physician or kept home to recover
- Restricted work or transfer imposed by the physician or employer
- Medical treatment beyond first aid
- Loss of Consciousness
- The injury is significant proclaimed by licensed health care professional
As for potentially needing to report the illness to OSHA, this can only be done if the employee dies of the coronavirus or ends up hospitalized. The same timeline rules apply here as well, death must be reported no later than eight hours after the employer gets word and hospitalization must be reported to OSHA within twenty-four hours.
All in all, the use of the 300, 300A, and 301 forms will keep the company in question compliant with OSHA regulations as well as provide much needed knowledge on hazards present in the workplace. With that information they will be able to better the company and make it much safer for employees.