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OSHA Recordkeeping Requirements (Updated for 2015 and 2016)

Quick Tips # 183
Introduction

The Occupational Safety and Health Administration’s (OSHA’s) recordkeeping requirements in place since 1971 (29 Code of Federal Regulations CFR Part 1904) are designed to help employers recognize workplace hazards and correct hazardous conditions by keeping track of work-related injuries and illnesses and their causes. These requirements were updated in 2002, 2015 and 2016.

2002 Changes
The 2002 revision was written in plain language using a question and answer format. OSHA Form 300 (Log of Work-Related Injuries and Illnesses), Form 300A (Summary of Work-Related Injuries and Illnesses) and Form 301 (Injury and Illness Incident Report) were introduced. The list of exempted industries was updated to reflect then recent industry data. The revised rule included provisions for recording needlestick and sharps injuries, musculoskeletal disorders (MSDs), standard threshold shift (STS) hearing loss cases and tuberculosis transmission cases. It also clarified the definition of restricted work or light duty making it easier to record those cases; promoted employee awareness and involvement in the process; and addressed employee privacy concerns. Medical treatment and first aid definitions were also modified to simplify recording decisions.

2015 Changes
In 2015, OSHA updated the recordkeeping rule to include two key changes. The first change updated the list of industries that are exempt from the requirement to routinely keep OSHA injury and illness records due to relatively low occupational injury and illness rates. The previous list of industries was based on the old Standard Industrial Classification (SIC) system and injury illness data from the Bureau of Labor Statistics (BLS) from 1996-1998. As of January 1, 2015, industries are based on the North American Industry Classification System (NAICS) and injury and illness data from BLS from 2007-2009. As a result of this movement to the NAICS classification some industries that were previously covered are no longer covered and some industries that were not previously covered are now covered. The new exemption list of NAICS codes is in Appendix A of the revised rule.

The second change expanded the list of severe work-related injuries and illnesses that all covered employers must report to OSHA. This revision retained the requirement to report all fatalities within 8-hours and added a requirement to report all inpatient hospitalizations, amputations and loss of an eye within 24-hours to OSHA.

Reporting Flowchart

Worker is Injured Reporting Flowchart Reporting Flowchart
Source: OSHA

2016 Changes
On May 12, 2016, OSHA published the new injury and illness reporting rule, known as "Improved Tracking of Workplace Injuries and Illnesses." This rule does not change the core requirements of the existing recordkeeping rule. The new rule, effective January 1, 2017, requires that the OSHA 300, 300A, or 301 forms be submitted to OSHA on an annual basis. The forms required are dependent on the size (number of employees) of each establishment covered. OSHA will make the data available online in a searchable database with all personal information removed.

The timeline for compliance is as follows:

Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit:

  • 300A forms covering calendar year (CY) 2016 by July 1, 2017
  • 300A, 300 and 301 forms covering CY 2017 by July 1, 2018
  • Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

Establishments with 20-240 employees in certain high-risk industries must submit:

  • 300A forms covering CY 2016 by July 1, 2017
  • 300A forms covering CY 2017 July 1, 2018
  • Beginning in 2019 and every year thereafter, the 300A forms must be submitted by March 2.

OSHA expects to collect about 1.6 million injury, illness and fatality data points from 464,000 establishments each year. OSHA expects to receive:

  • 720,000 detailed injury and illness cases from about 34,000 establishments with 250 or more employees
  • 930,000 summary cases from about 430,000 establishments with 20-249 employees.

Scope of Recordkeeping Standard
Employers are classified by OSHA’s injury and illness recordkeeping requirements into one of three groups: employers regularly exempt from OSHA recordkeeping; employers exempted from preparing and maintaining injury and illness records; and employers that are not classified under the prior two groups.

Employers regularly exempt from OSHA recordkeeping includes small businesses with fewer than 11 full- or part-time employees during the previous calendar year and employers classified in low-hazard industries. However, these employers are required to report all inpatient hospitalizations and fatalities as required by 29 CFR 1904.39. In addition, if the employer is notified in writing by OSHA to participate in a statistical survey, the employer must maintain injury and illness records in accordance with 29 CFR 1904.

Employers exempted from preparing and maintaining injury and illness records include industries listed in Appendix A of Subpart B of the revised recordkeeping standard.

Employers that are not classified under either of the two groups mentioned above are required to comply with the guidelines of 29 CFR 1904.

OSHA Form 300

The OSHA Form 300 log is used by each employer’s establishment to record and maintain information about employee injuries and illnesses. An establishment, as defined by OSHA, is a single physical location where business is conducted, or where services or industrial operations are performed; the place where employees report for work, operate from or from which they are paid.

The form itself is divided into three general sections: Identity (e.g. name, case number, job title), Descriptive (e.g. date, injury location, description of incident) and Classification (e.g. type of injury, days away from work, days on restriction). The following is a list of guidelines to use for maintaining an OSHA Form 300 log:

  • Maintain OSHA Form 300 log on a calendar year cycle (not fiscal).
  • Record cases within seven calendar days of receiving information that a recordable case has occurred.
  • Retain OSHA Form 300 log for five years following the calendar year to which it relates.
  • Maintain OSHA Form 300 log during those five years and add or delete cases as necessary.
OSHA Form 301

If an injury or illness is recordable, a supplementary form (e.g. OSHA Form 301) must be completed. This form provides more information about the case. Such information as the events leading up to the injury or illness, body parts affected, object(s) or substance(s) involved, etc., must be included on this form.

OSHA Form 301 is only suggested. A different form may be used if it contains the same information as OSHA Form 301. Other suitable forms are: state workers’ compensation reports, insurance claim reports or the employer’s accident report form.

The following is a list of guidelines to use for maintaining supplementary records:

  • Record cases within seven calendar days of receiving information that a recordable case has occurred.
  • Keep OSHA Form 301 current within 45 days at any given time.
  • Each establishment must maintain an OSHA Form 301 or similar form.
  • Retain records for five years following the calendar year to which they relate.
Process to Determine if a Case is Recordable

Employers are responsible for reporting all recordable injuries and illnesses. To help determine if an injury or illness is recordable, refer to the flow chart below. If you are unable to determine if an injury or illness is recordable, call the OSHA area office nearest you.

Source: OSHA

Definitions
  1. Employee Report of Injury/Illness: Injury or illness reported assumes the individual reporting the injury or illness is an employee of host employer. If the employee is a temporary employee from a temporary staffing agency, incidents are to be recorded in the OSHA Form 300 log; however, the temporary staffing agency would be responsible for reporting workers’ compensation claims to the carrier.
  2. Occupational Hearing Loss: Defined as:
    1. A change in hearing threshold relative to the baseline audiogram as an average of 10 decibels (dB) or more in either ear at 2000, 3000 and 4000 hertz.
    2. An employee’s total hearing level of 25dB or more above audiometric zero in both ears at the same hertz levels.
  3. Medical Treatment: The management and care of a patient to combat disease or disorder. It does not include:
    1. Visits to practitioners for observation and/or evaluation only
    2. Diagnostic procedures
    3. First aid
  4. First Aid: Treatments that are considered first aid include:
    1. The use of nonprescription medication at nonprescription strength
    2. Tetanus immunizations
    3. Cleaning, flushing or soaking surface wounds
    4. Use of wound coverings, butterfly bandages, Steri-Strips tape
    5. Hot or cold therapy
    6. Use of nonrigid means of support
    7. Temporary immobilization devices used to transport victims
    8. Drilling of fingernails, toenails or draining fluid from a blister
    9. Eye patches
    10. Removal of foreign bodies from eye using irrigation or cotton swab
    11. Removal of splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
    12. Finger guards
    13. Massage therapy
    14. Drinking fluids for relief of heat stress
OSHA Form 300A

The employer is responsible for preparing an annual summary of injuries and illnesses that occurred during the calendar year. The annual summary, OSHA Form 300A, displays the totals from columns G through M of the OSHA Form 300 log. The summary also displays the calendar year covered, company name and address, annual average number of employees and total hours worked by all employees covered by the OSHA Form 300 log. OSHA Form A is a separate form and does not display any of the personal information, shown on the OSHA Form 300 log. OSHA Form 300A also makes it easier to calculate incident rates. The annual summary must be:

  • Posted by February 1 and remain posted until April 30
  • Posted in areas where other notices are normally placed
  • Certified (signed) by a company executive, stating that the information is correct and complete to the best of the employer’s ability
  • Retained for five years following the calendar year to which they relate. If no cases are recorded during a reporting period, a summary must still be posted. Zeroes should be entered into all spaces provided on OSHA Form 300A.
Commonly Asked Questions
 
Q. Where can I get a copy of OSHA Form 300, 301 and 300A?
A. Contact the area OSHA office nearest you, or download the information off of the OSHA website at www.osha.gov.
 
Q. What is restricted work activity?
A. When the employee is kept from performing one or more routine (regularly performed at least once per week) functions of his or her job, or when the employee is kept from working a full workday. Production of fewer goods or services is not considered restricted work activity.
 
Q. Our company is closed on Saturday and Sunday. Do these still need to be counted as days away?
A. Yes, all calendar days the employee was unable to work including weekend days, holidays, vacation days, etc., must be counted. Cap day count at 180 days. The day the illness or injury occurred is not counted as a day away.
 
Q. If an employee is injured and misses the remainder of the work shift, is this a day away?
A. No, injuries and illnesses are not considered lost-time cases until they affect the employee beyond the day of injury or onset of illness.
 
Q. How are days away calculated if an employee works a normal shift that is longer than 8 hours?
A. A single workday for recordkeeping purposes is 12 hours.
 
Q. Does the tracking of workplace injuries and illnesses rule require employers to start keeping new records or change how they keep the records?
A. No. The new requirement does not add to or change an employer's obligation to complete, retain, and certify injury and illness records. It only requires certain employers to electronically submit some of the information from these records to OSHA.
 
Q. Are the electronic reporting requirements based on the size of the establishment or the firm?
A. The electronic reporting requirements are based on the size of the establishment. The OSHA injury and illness records are maintained at the establishment level. An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed. A firm may be comprised of one or more establishments. To determine if you need to provide OSHA with the required data for an establishment, you need to determine the establishment's peak employment during the last calendar year. Each individual employed in the establishment at any time during the calendar year counts as one employee, including full-time, part-time, seasonal, and temporary workers.

 

Sources for More Information

OSHA FactSheet: Updates to Recordkeeping Rule: An Overview

OSHA FactSheet: Final Rule to Improve Tracking of Workplace Injuries and Illness, May 2016
U.S. Department of Labor
September 2014

OSHA – Report a Fatality or Severe Injury

OSHA Injury and Illness Recordkeeping and Reporting Requirements

(Rev.10/2016)


Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.

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Please Note:
The information contained in this publication is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This publication is not a substitute for review of the current applicable government regulations and standards specific to your location and business activity, and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.


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