OSHA is changing its policies on injury and illness reporting and recordkeeping. Read on to learn how the new updates will affect your facility and when you’ll have to comply.
Beginning in 2017, employers with more than 250 employees and those with 20 to 249 employees in specified high-risk industries must submit injury and illness logs annually to the Occupational Safety and Health Administration (OSHA). The information that OSHA obtains from these documents helps them to evaluate the overall safety of workplaces, establish trends and target their outreach efforts to industry sectors with higher than average incident rates.
Any injury that is work-related [29 CFR 1904.5] and is a new case [29 CFR 1904.6] must be reported if it meets any of the following criteria:
- 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 sharps injuries
- Occupational hearing loss
- Occupational exposure to tuberculosis
Not every injury is recordable. Injuries and illnesses that only require first aid treatment do not need to be recorded in OSHA logs. The following actions are considered to be first aid treatment and do not need to be recorded in OSHA logs [29 CFR 1904.7(b)(5)(ii)]:
- Using a nonprescription medication at nonprescription strength
- Administering tetanus immunizations
- Cleaning, flushing or soaking wounds on the surface of the skin
- Using wound coverings (such as bandages, Band-Aids® and gauze pads) or using butterfly bandages or Steri-Strips™
- Using hot or cold therapy
- Using any non-rigid means of support, such as elastic bandages, wraps and non-rigid back belts
- Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.)
- Drilling of a fingernail or toenail to relieve pressure or draining fluid from a blister
- Using eye patches
- Removing foreign bodies from the eye using only irrigation or a cotton swab
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
- Using finger guards
- Using massages
- Drinking fluids for the relief of heat stress
It is important for employers to keep accurate records and to submit their reports annually if they are required to do so.
Some injuries, however, must be reported to OSHA in a timelier manner. If there is a fatality, OSHA must be informed within eight hours. If an employee is hospitalized, suffers an amputation or the loss of an eye, a report must be filled within 24 hours. OSHA maintains a 24-hour hotline at 1-800-321-6742 to allow employers to provide timely reporting of these types of incidents.
To facilitate recordkeeping and help ensure that information is consistently tracked, OSHA has three different types of forms to record workplace injuries and illnesses.
OSHA Form 300: The Log of Work-Related Injuries and Illnesses
The OSHA 300 log is used to keep track of all recordable workplace injuries and illnesses throughout the year. It needs to be kept current and must be made available to OSHA compliance officers within four hours of a request. OSHA 300 logs must be electronically submitted to OSHA annually beginning in 2018 if the facility has 250 or more employees, 20 to 249 employees in designated industry sectors or if OSHA specifically requests it. Facilities must also keep this record onsite for five years.
The log includes information about who was injured, the type of injury or illness and what happened as a result of it: death, days away from work or duty restrictions, for example. OSHA clarifies how days away from work are to be recorded in 29 CFR 1904.7(b)(3).
OSHA Form 301: The Injury and Illness Incident Report
For each injury or illness reported on the 300 Log, a Form 301 must be completed [29 CFR 1904.29(b)(2)]. This form must be completed within seven days following an incident and must be kept for five years.
The 301 form provides details about the injury or illness that has occurred. This helps the employer recall facts about an event if they are needed at a later time and provides OSHA with specific information about how an injury or illness happened. Like the Form 300, beginning in 2018 workplaces with 250 or more employees will need to submit this log to OSHA annually.
OSHA Form 300A: The Summary of Work-Related Injuries and Illnesses
From February 1 to April 30 of each year, a summary of all recordable injuries and illnesses (the OSHA Form 300A) must be posted in the workplace. It must be posted in places where other notices are typically posted and it cannot be altered, defaced or covered by other announcements or materials [29 CFR 1904.32(b)(5)]. You must also have a means of verifying that the information was posted in the workplace, such as a notice in employee bulletins or a dated photograph.
All facilities subject to electronic recordkeeping rules must submit this form annually beginning in January 2017.
If workplace injuries or illnesses do occur, OSHA gives employees the right to report work-related injuries and illnesses and to do so without fear of retaliation. Employers must have a reasonable process for reporting injuries and illnesses and that process must be communicated with employees.
No employee should expect to be injured. That’s why OSHA takes recordkeeping seriously and requires employers to identify workplace hazards and put processes, procedures and safeguards in place to prevent injuries and illnesses. OSHA also requires employers to train their employees about hazards they may face and how to prevent them.
Requiring employers to submit their injury and illness records provides OSHA with valuable information that can be used to focus their efforts on rulemaking, guidance documents and outreach programs that help prevent future workplace incidents.
Wondering what OSHA will be looking for when an inspector shows up at your facility? Check out the OSHA Top 10 Violations list, updated every year in October, to see where most facilities fall short and get fines.