OSHA Injury and Illness Recordkeeping and Reporting Requirements

June 06, 2022 5 min read

According to the Bureau of Labor Statistics, employer-reported nonfatal workplace injuries and illnesses in 2020 dropped to 2.7 million from 2.8 million in 2019. Another good news is that a 10.7 percent decrease in fatal work injuries was recorded between 2019 and 2020. The decline in work-related injury and illness cases was due to a drop in injury cases as reported by industry employers.

Through efficient reporting and recording of workplace injury and illness, government agencies and other industries are informed about the needs and improvements in workplace safety.

OSHA requires employers with more than ten employees to keep a record and report serious work-related injuries and illnesses. This information helps employers, employees, and OSHA to assess workplace safety and health, understand industry hazards, and effectively implement worker protections to prevent future workplace injuries and illness. This article presents OSHA requirements for recordkeeping and reporting.

OSHA Recordkeeping Requirements

Recordable Injury and Illnesses

Before anything else, it is essential to identify when is an injury or illness considered work-related. An injury or illness caused by an event or exposure in the work environment is considered work-related. Moreover, if the work environment contributed to the condition or aggravated a pre-existing condition, the injury or illness is still regarded as a work-related incident.

OSHA defines a recordable work-related injury or illness if it results in a fatality, loss of consciousness, days away from work, restricted work or transfer to another job, requiring medical treatment beyond first aid, diagnosis of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums. Cases related to needlesticks and sharps injuries, medical removal, hearing loss, and tuberculosis should also be recorded according to their specific recording criteria.

Although OSHA requires employers with more than ten employees to keep injuries and illness records, employers classified in the North American Industry Classification System (NAICS) are partially exempted from the OSHA requirement. These are low-risk industries when it comes to causing lesions and illnesses to their employees.

Five Steps in OSHA Injury and Illness Recordkeeping

Five Steps in OSHA Injury and Illness Recordkeeping

Work-related injuries and illness records should be maintained at the worksite for at least five years. Employers are also required to post a summary of the recorded injury and illnesses from the previous year every February through April. OSHA also noted that if requested, employers should provide copies of the records to current and former employees or their representatives.

OSHA outlined five main steps for injury and illness recordkeeping:

  1. Acquire a detailed report of every work-related injury or illness that requires medical treatment (beyond first aid treatment) in the workplace. 

  2. Record every job-related injury or illness on OSHA Form 300, strictly following the instructions outlined in the form.

  3. Provide supplementary records of the injuries and illnesses using OSHA Form 301.

  4. Create an annual report using OSHA Form 300A, summarizing the recorded occupational injuries and illnesses. Post it on February 1 and keep it posted until April 30. OSHA suggests posting this report next to the OSHA Workplace Poster.

  5. Keep these records for at least five years.

List of Recordkeeping Forms

Different forms were mentioned in the steps of recordkeeping occupational injuries and illnesses.

OSHA Form 300 is for employers to record all reportable injuries and illnesses that happened in the workplace; where and when they occurred; the case’s nature, the name and job title of the involved employee, and the number of days away from work or on restricted or light duty, if necessary. Basically, this form is the OSHA Log of Injuries and Illnesses.

Aside from OSHA Form 300, other forms used for recordkeeping are the OSHA 301 and 300A. Form 301, also known as the Injury and Illness Incident Report, records information on how every injury or illness case happened. As the name implies, this form acts as the incident report record.

Called the Summary of Work-Related Injuries and Illnesses, Form 300A is an annual report that summarizes all the recorded injuries and illnesses. The OSHA Form 300A must be completed and certified at the end of each calendar year. Posting would be from February 1 to April 30 as per OSHA’s requirement.

OSHA Reporting Requirements

Reporting Flowchart

There are differences when it comes to OSHA reporting; therefore, it is crucial to reach out to a consultant or directly to OSHA to determine the correct protocol for reporting job-related injuries and illnesses. Nevertheless, OSHA provided a reporting flowchart that shows a timeline of when to report work-related injury and illness.

OSHA Reporting Flow Chart

As shown in the flowchart, if the injury is fatal, OSHA requires that a report be made within eight hours. If the employee was hospitalized, amputated, or lost an eye, employers should report to OSHA within 24 hours. However, if the employee was injured, but the said conditions did not occur, then reporting is not required. Nevertheless, after reporting, a thorough incident investigation should follow.

Severe Injury Reporting

Although some employers are exempt from OSHA injury and illness recording requirements, OSHA makes it clear that they are not exempt from specific reporting requirements.

For example, all employers, including those partially exempted for recordkeeping because of company size or under the NAICS, must report any workplace incident that leads to a fatality, in-patient hospitalization, amputation, or loss of an eye.

To make a report, OSHA recommends:

Electronic Reporting Requirements

Electronic Reporting Requirements

The federal agency published a final rule for some employers to submit their injury and illness records to OSHA through the Injury Tracking Application (ITA). The ITA page allows employers to provide OSHA with their Form 300A information. Electronic reporting aims to enhance OSHA’s ability to identify establishments that experience high rates of work-related injuries and illnesses.

Electronic Reporting Requirements are based on the size of the establishment. According to OSHA, establishments with 250 or more workers required to keep OSHA injury and illness records or establishments with 20 to 249 employees under certain industries such as utilities, construction, manufacturing, and others, should submit their Form 300A electronically to OSHA.

These establishments must submit their Summary data through the ITA every March 2nd of the year after the calendar year covered in the form or whenever requested by OSHA.

Conclusion

Recently, OSHA published a proposed rule that aims to improve the tracking of workplace injuries and illnesses. It is expected that this rule will continue to enhance efficient recordkeeping and reporting of occupational injuries and illnesses.

Aside from OSHA, employers benefit the most from complying with this OSHA standard. Records and reports on workplace injuries and illnesses give employers insights on protecting their workers, reducing the risk of job-related injury or illness, and providing information to keep the workplace environment as safe as possible for everyone.

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Herbert Post

Born in the Philadelphia area and raised in Houston by a family who was predominately employed in heavy manufacturing. Herb took a liking to factory processes and later safety compliance where he has spent the last 13 years facilitating best practices and teaching updated regulations. He is married with two children and a St Bernard named Jose. Herb is a self-described compliance geek. When he isn’t studying safety reports and regulatory interpretations he enjoys racquetball and watching his favorite football team, the Dallas Cowboys.


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