Each year, more than 5,000 U.S. workers are killed and more than 2 million are injured or made ill on the job. When occupational injuries, illnesses or fatalities happen, OSHA has specific requirements for reporting and recording these incidents.
Reporting and recordkeeping are terms that can sometimes be used interchangeably, but each has a specific meaning when it comes to documenting employee injuries, illnesses and fatalities. Each also has specific requirements and applicability in workplaces.
Since the 1970’s, facilities with 10 or more employees have been required to keep three types of records of occupational injuries, illnesses and fatalities, unless they are an exempted low-risk industry. Until recently, employers did not have to submit any of these records unless requested by OSHA or the Bureau of Labor Statistics.
Although they are a lagging indicator, injury, illness and fatality records can help employers track the types and rates of incidents that have occurred at their facility and determine if new safety programs and efforts that have been implemented are effective in reducing injury and illness rates.
OSHA Form 300A: The Summary of Work-Related Injuries and Illnesses
This record summarizes the number of fatalities, injuries and illnesses that have occurred in the previous year. By March 2 of each year, employers with more than 250 employees and those with 20-249 employers in high risk occupations must electronically submit their Form 300A log to OSHA. Employers must submit this form even if there were no injuries, illnesses or fatalities at their facility in the previous year.
In addition to filing the report with OSHA annually, a copy of Form 300A must be posted in the workplace from February 1 to April 30 of each year. Employers should have a means of verifying that the form was posted for employee review. Form 300A logs must be kept for five years.
OSHA Form 300: The Log of Work-Related Injuries and Illnesses
The OSHA 300 log is similar to the Form 300A in that it is a summary log. This record is used by regulated facilities to keep track of all recordable workplace injuries and illnesses throughout the year. It contains greater detail than the Form 300A, such as the name of the person injured, the nature of the incident, where it occurred and what happened as a result of the incident, such as days away from work, restricted duty, etc.
Although employers do not need to submit this form to OSHA annually, it must be kept current and be made available to OSHA compliance officers within four hours of a request. Facilities must keep their 300 logs onsite for five years.
OSHA Form 301: The Injury and Illness Incident Report
For each injury, illness or fatality that is reported on the 300 Log, a Form 301 must be completed within seven days following an incident [29 CFR 1904.29(b)(2)].] Like the other records, these forms must be kept for five years.
The 301 form is a record that provides specific details about each injury, illness or fatality. The purpose of this is to help the employer recall facts about an event and provide OSHA with specific information about how an incident happened.
Not every injury or illness that happens at work is recordable. Injuries and illnesses that only require first aid do not need to be recorded in OSHA logs. The following actions are all considered first aid and do not need to be recorded in OSHA logs [29 CFR 1904.7(b)(5)(ii)]:
- Using non-prescription medications at non-prescription strength
- Administering immunizations
- Covering wounds with bandages, gauze pads or butterfly bandages
- Using heat or cold therapies
- Using non-rigid supports that do not immobilize a body part
- Drilling a fingernail or toenail to relieve pressure
- Draining fluid from a blister
- Using temporary immobilization devices while transporting an accident victim
- Eye patches
- Removing foreign objects from the eye using irrigation or a cotton swap
- Removing splinters with tweezers, cotton swaps or irrigation
- Using finger guards
- Drinking fluids to relieve heat stress
As a best practice, some facilities record events like these as “near misses” in a separate database or in a separate record from required OSHA logs. Recording first aid incidents can help to identify injury trends or areas of improvement that may be undertaken to avoid more severe, recordable injuries.
Recordable events include fatalities and any occupational injury or illness that results in:
- Days away from work, restricted work or transfer to another job
- Medical treatment beyond first aid
- Loss of consciousness
- Work-related diagnosed case of cancer or a chronic irreversible disease
- Fractured or cracked bones or teeth
- Punctured eardrums
- Needlestick exposures and sharp injuries
- Occupational hearing loss
- Occupational exposure to tuberculosis
These types of injuries must be included in the numbers submitted on the 300A log. They must also be included on the 300 log that is kept at the facility with accompanying 301 reports.
Fatalities and certain types of serious injuries must be reported directly to OSHA in a more timely manner than the annual 300A report.
- Fatalities (report within 8 hours)
- Amputations (report within 24 hours)
- Loss of an eye (report within 24 hours)
- Hospitalization of a worker (report within 24 hours)
OSHA maintains a 24-hour hotline at 1-800-321-6742 for employers to provide timely reporting of these types of incidents. OSHA investigates these incidents promptly – usually within 24 hours.
OSHA takes recordkeeping and employee rights very seriously. All employees have the right to report work-related injuries and illnesses to their employer and directly to OSHA without fear of retaliation.
Employers must have a reasonable process for reporting injuries and illnesses and must communicate that process with employees. Copies of OSHA recordkeeping forms must also be made available to employees and their representatives upon request [29 CFR 1904.35(b)(2).]
No one expects to be injured or killed on the job, but, unfortunately, workplace incidents still happen. Recording and reporting these injuries correctly helps OSHA identify high-risk occupations and provide better safeguards for all employees.