OSHA Record-Keeping Tips

What do you think of when you hear “OSHA Recordkeeping?”

Many automatically think it’s something the EHS or Safety Department manages. This may be the case, but management should be involved as well. Employers must certify and post their OSHA 300A (annual summary) by February 1 every year. With few exemptions, OSHA requires employers in all industries to record and report injuries and illnesses. 

Employers should keep in mind that, “Recording or reporting a work-related injury, illness, or fatality does not mean that the employer or employee was at fault, that an OSHA rule has been violated, or that the employee is eligible for workers’ compensation or other benefits.” An OSHA recordable injury/illness simply indicates that an employee experienced a work-related event/exposure, it’s a new case, and it met OSHA recording criteria.

Why are employers required to maintain specific OSHA forms/records? The simple answer is, because OSHA says so, but the real reason is to be able to review trends on the injuries or illnesses. For example, if one department has multiple hand/finger injuries, management should focus on that department’s processes and procedures, then review similar exposures throughout their operations and implement preventive actions.

OSHA forms

There are three forms to maintain for each calendar year: 300 Log, 300A, and 301 Incident Report. Recordable injuries/illnesses must be entered on the 300 Log within seven calendar days of receiving the necessary information. The cases from the 300 Log are reported on the 300A annual summary, which is certified by a company executive and posted in a conspicuous location February 1 through April 30. A common misunderstanding with the 300A is who is required to certify it. OSHA requires a company executive to certify the 300A because they expect the “head honcho” to understand the number of OSHA recordable injuries/illnesses experienced at their establishment. Unless the Safety Manager or HR Manager meets OSHA’s definition of a company executive, they should not sign the 300A annual summary.

You must retain all three forms for five years following the end of the calendar year that these records cover. During an OSHA inspection, an employer has four hours to provide the records.

OSHA does not require near-miss events or first-aid-only injuries to be recorded. However, employers have found that investigating these events can dramatically reduce recordable injuries. The conditions, actions, and contributing factors are investigated, which allows management to implement corrective and preventive actions to avoid future events and injuries.

What’s considered a recordable injury/illness that should be recorded in the OSHA 300 Log? The quick, but not always easy, answer: It’s work-related, it’s a new case, and it meets general recording criteria. The basis for these criteria includes a death, days away from work, job transfer or restriction, a loss of consciousness, or other recordable case. Other recordable cases typically require medical treatment beyond OSHA’s definition of First Aid.

Finally, which recordable injuries/illnesses must be reported to OSHA? Within eight hours after the death of an employee, because of a work-related incident, OSHA must be contacted by telephone. In 2015 OSHA updated the reporting requirements to include other incidents. These incidents are the in-patient hospitalization of one or more employees, an employee amputation, or an employee loss of an eye because of a work-related incident. These incidents must be reported within 24 hours by telephone or using OSHA’s electronic-submission form. EP 

For more information and assistance, visit osha.gov.

Vince Plank is a Safety Advisor at Safety Management Group, Indianapolis, IN, (safetymanagementgroup.com). He is a Certified Safety Professional with almost 20 years of occupational safety and health experience in general industry and construction. Contact him at VincePlank@safetymanagementgroup.com.