First, let us differentiate between OSHA “Recordkeeping” and “Reporting”. OSHA requires that any work related employee injury that meets any of the following criteria must be “Reported” to the local area OSHA office:
Within 8 hours of the employer receiving notice:
Work related fatality.
Within 24 hours of the employer receiving notice:
Employee hospitalization
Amputation of a body part
Loss of an eye
In terms of “Recordkeeping”, OSHA requires all employers with 10 or more employees to record annually all work related injuries on an OSHA 300 Log. This log is a helpful tool in tracking reportable injuries and illnesses that have occurred in the workplace. It also is a helpful tool in identifying trends associated with employee injuries.
At the end of the year, the statistics from the OSHA 300 Log are transferred to the 300 A Summary Log. That summary log is then required to be visibly posted in the workplace where all employees have access (i.e. bulletin board) from February 1st through April 30th. The 300 A Form is a summary including the total number of days away from work, number of injuries, total work hours etc. throughout the year without detailing names or personal information of the employees who were injured.
Physical OSHA Logs are to be recorded and maintained for 5 years.
The first step in recording employee injuries is to determine if the injury is “work-related”. It takes time and investigation skills to determine if an injury is work-related or not. An injury or illness is considered work-related if an event or exposure in the work environment caused or contributed to an injury/ illness or aggravated something that was pre-existing. A formal investigation process helps with determining the root cause of the incident.
Next Steps:
Many employers in certain industries such as, agriculture, construction, manufacturing, with 20-249 employees are required to submit electronically the information from their Form 300A Summary to OSHA. To find out if your industry is included, this is a list of industries that are classified with historically high rates of occupational injuries and illnesses. Certain state plan OSHA states have to report this data online regardless of industry, check the state regulations in your area.
FAQ Tool:
OSHA developed an FAQ tool on the Injury and Illness Recordkeeping and Reporting Requirement page to help employers search for answers regarding recordkeeping requirements. This link will allow you to search a repository of questions and answers from the regulation rule. By typing key words into the search field, you can view a list of questions asked by employers all over the country and the subsequent answers given by OSHA. If your question is not found on the page, your own personal questions can be submitted using the OSHA’s e-correspondence form.
Should you have any recordkeeping questions please feel free to reach out to your local MMA safety consultant or email consulting.safety@marshmma.com.
