environmental

5 Takeaways from “OSHA Recordkeeping Standards: Your Guide to Compliance”

Phil Molé, MPH, our resident EHS and Sustainability Expert, recently hosted a webinar explaining OSHA’s Recordkeeping Standards. In this webinar, he goes into depth about why it is important to properly fill out each form, discusses common mistakes, and what OSHA considers a recordable vs non-recordable injury along with compliance best practices.

In what follows, we’ll discuss these 5 key takeaways from the presentation:

  1. Importance of Recordkeeping
  2. Needed Forms to be Submitted: 300, 300A, and 301
  3. Common Mistakes
  4. Recordable Non-Recordable Cases
  5. Best Practices

Importance of Recordkeeping

OSHA’s Recordkeeping Standard covers over 750,000 employers and 1.5 million establishments, helping to make sure work environments are safe for its employees. To ensure this, OSHA requires covered employers to record and report work-related injuries and illnesses. This provides OSHA with needed information so they can:

  • Assess whether standards are improving safety as expected or whether new standards are needed
  • Properly allocate resources
  • Budget inspections and enforcement time
  • Assess eligibility for the Voluntary Protection Program (VPP)
  • Determine “low-hazard” industry exemptions for standards

Recordkeeping not only benefits OSHA, but also benefits employers and employees. It allows employees to better understand how the company is performing in regard to safety and what is being done to mitigate hazards in the workplace. Through recordkeeping, the company can be more proactive in continuous improvement of the workplace ensuring the safety, health, and wellness of its employees.

Needed Forms to be Submitted: 300, 300A, and 301

There are three forms that need to be submitted. The first is OSHA Form 300, a log of work-related injuries and illnesses. The second form is 301, the injury and illnesses incident report, which employers must complete for each individual recordable injury or illness. The third is 300A, a summary of work-related injuries and illnesses. Keep in mind if a company has an incident that meets one or more OSHA recording criteria, it must enter the details on Forms 300 and 301.

Here is some additional information about each of the forms:

  • Form 300—Log of Work-Related Injuries and Illnesses
    • Logs the incident that occurred
    • Classifies work-related injuries and illnesses in provided columns
    • Documents the extent and severity of injuries and illnesses
    • Provides details about employee(s) involved, but excludes names for privacy
    • Classifies the injury or illness based on the most serious outcome (Employers should be careful to check only one box in the “Classify the Case” section)
    • Includes a count of “days away from work” or the days spent “on job transfer or restriction” for each case. The employer must be sure to count all calendar days starting with the day after the incident occurred, including weekends and holidays, and cap the count at 180 days
    • Needs to be kept on file and must be kept up to date as new incidents occur, or as new information comes in about existing incidents
  • Form 301—Injuries and Illnesses Incident Report
    • Captures the detailed information about the incident
    • Includes details that the 300 Form does not, such as
      • Physician contact information
      • Whether the incident resulted in an overnight hospitalization or emergency room visit
      • Descriptive explanations of the incident
    • Provides employer with important information needed to prevent similar incidents from happening
  • Form 300A—Summary of Work-Related Injuries and Illnesses

(Employers must complete, sign, and post this form in their establishment by February 1)

  • Contains a numerical summary of incidents
    • Tallies total number of cases within specific categories including occupational fatalities, hearing loss cases, and poisonings. Tallies total numbers of days away from work, or days spent on job transfer or restrictions
  • Must be signed by a company executive and posted annually in a location that is clearly visible to employees from February 1 to April 30 each year
  • Must remain on file and must be kept up to date. Note that employers at establishments subject to the electronic reporting requirement must also electronically transmit this information to OSHA via the Injury Tracking Application (ITA) by March 2. An establishment is subject to this requirement if it is part of a company covered by the Recordkeeping Standard and has 250 or more employees, or 20 or more employees if it is in a high-risk industry sector

There are a few things to remember when filling out these forms. Employers must fill out separate forms for each establishment, unless an establishment has been open for less than one year, in which case they can account for the occupational injuries and illnesses on combined forms. Establishments must retain copies for five years following the year of the recorded incident and must make the forms accessible. Employers must record each recordable injury or illness on Forms 300 and 301 within seven days of learning of the incident.

Common Mistakes with OSHA Recordkeeping

There are some common mistakes that occur when maintaining and keeping records for OSHA. One of the biggest mistakes is under-recording work-related injuries and illnesses that meet recordable criteria—meaning that the employer should have recorded the cases on their recordkeeping log(s) but did not.

A second common mistake is under-reporting, such as reporting inaccurate numbers and severity of workplace injuries and illnesses to regulators or failing to report several categories of serious injuries to OSHA. All employers covered by the Occupational Safety and Health (OSH) Act must report occupational fatalities to OSHA within 8 hours and must report any incidents involving a hospitalization, amputation, or loss of eye within 24 hours.

Some other common mistakes include:

  • Forgetting to sign the 300A
  • Double counting a case both “days away “and “restricted”
  • Counting workdays instead of calendar days when counting days away or restricted days
  • Neglecting to include injuries/illnesses for temp/contract workers
  • Forgetting to record within seven days
  • Failing to report enough specific details, or mistaking an OSHA recordkeeping rule with a workers’ compensation law

Awareness of these common mistakes can help to avoid them.

Recordable vs Non-Recordable Cases

OSHA has a recordable decision tree available on its website to help employers determine if injuries or illnesses are recordable. The tree consists of four questions, and if you answer “yes” to all four then it’s recordable. If the answer is “no” to any of them, you don’t have a recordable injury or illness.

The questions are:

  1. Did the employee experience an injury/illness?
  2. Was it work-related?
    • The concept of “geographic presumption” is relevant here, meaning that the event or exposure that caused the injury or illness occurred in the physical place where the employee works. Geographic presumption encompasses not only the specific area of the establishment where the employee works, but also encompasses all the buildings, the break and landscaped areas, and walkways and parking areas
  3. Is the event or exposure a new case? Consider the case “new” only if:
    • The employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body; or
    • The employee previously experienced a recorded injury or illness of the same type that affect the same part of the body but had recovered completely prior to injury or illness
  4. Does the injury or illness meet the general or the specific additional recording criteria?

The general recording criteria are:

  • Medical treatment beyond first aid
  • Loss of consciousness
  • Days away from work/restricted work
  • Diagnosed by licensed healthcare professional as a significant injury or illness
  • Death

A common recent OSHA Recordkeeping question we often get is: “Are COVID-19 illnesses recordable cases?” In short, COVID-19 can be a recordable case if the exposure takes place in the workplace and meets one of the general recording criteria, such as resulting in hospitalization. According to OSHA guidance, they expect the employer to do a reasonable investigation to determine work-relatedness and identify whether the exposure occurred in the workplace, and will take enforcement discretion based on their review of the employer’s investigation.

OSHA Recordkeeping Best Practices

Now that we’ve covered the basics, let’s share some best practices you can use to help maintain compliance with the Recordkeeping Standard.

To improve your recordkeeping practices, follow these four steps:

  1. Determine responsibility for your recordkeeping program
    • Set up a recordkeeping system that works for your organization
    • Create reporting rules for incident notification, and make sure your employees understand them
      • Centralize recordkeeping into one system. Consider a software-based incident management system that makes it easier to track all incidents, whether recordable injuries or illnesses, near misses, or first aid cases, and lets employees submit hazard observations to identify risks before an incident happens
  1. Create a written injury and illness prevention program. Some states actually require employers to have one, and many employers will find that a written program will sharpen their incident management practices and improve buy-in from employees. If you do create one, be sure to draft and internally publish the details of it and key incident metrics to maximize its effectiveness
  2. Ensure facilities maintain recordkeeping forms and related documents. Remember, each establishment that has been open for one year or longer must have its own forms
  3. Utilize available resources, including informational resources like those on OSHA’s Recordkeeping Page and tools such as modern incident management software

Looking for More Information?

This is just a sampling of some of the information you’ll find in our OSHA Recordkeeping webinar. If you missed it this time, don’t worry—you can catch our next live presentation on February 15. Register at the link below!

OSHA's Recordkeeping Standard: Your Guide to Compliance

Let VelocityEHS Help!

We’re always happy to discuss how our Incident Management Software can help you meet your requirements under the Recordkeeping Standard, including the ability to quickly generate and submit electronic 300A data. Contact us anytime to learn more.

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