The Ultimate Guide to OSHA Recordkeeping in 2022

The Ultimate Guide to OSHA Recordkeeping in 2022
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August 10, 2018

Resource: Blog Industry: Multiple Industries
Tags: Vector EHS Management

When it comes to OSHA recordkeeping there are always questions regarding the requirements and in and outs. Vector Solutions is here to help. We put together this page with critical information that’s easy to digest. This guide will help answer your key questions about OSHA recordkeeping, including:

  • Who is required to complete OSHA recordkeeping?
  • What is an OSHA recordable incident?
  • Do I need to record employee exposures to Coronavirus (COVID-19)?
  • What are the recordkeeping logs?
  • Do I have to submit data electronically to OSHA?
  • What are the continued changes in rulemaking from OSHA for electronic submissions?
  • What does TCIR Rate have to do with it?

No time to read?

You can download all the information from our guide as a comprehensive PDF.

 

Is my company required to complete OSHA recordkeeping?

Organizations in high risk industries with more than 10 employees are required by the Occupational Safety and Health Administration (OSHA) to track work-related employee injuries and illnesses according to OSHA recordkeeping requirements.  Organizations covered under OSHA must complete three recordkeeping logs for all work-related OSHA recordable injury and illnesses.

If your organization has 10 or fewer employees — including temporary and contract workers — or if you are part of a low-hazard industry that has been exempt according to your company's NAICs code, you don't have to keep OSHA injury and illness records.

However, all organizations covered under OSHA still must comply with OSHA Reporting requirements. This means that you must report directly to OSHA if a fatality, in-patient hospitalization, amputation, or loss of an eye occurs at your establishment due to a work-related incident.

Organizations in a few high risk industries such as railroading or mining are not covered under OSHA regulations but are required to complete injury and illness reporting requirements to the appropriate regulatory agencies such as the Mine Safety and Health Administration (MSHA) or the Federal Railroad Administration (FRA).

What is an OSHA Recordable Injury? Woman with arm in cast, seated with medical professional

What is an OSHA Recordable Injury?

An OSHA recordable injury has to be work-related and results in any of the following circumstances:

  • Death
  • Loss of consciousness
  • Days away from work
  • Restricted work activity or job transfer
  • Medical treatment beyond first aid
  • Additional criteria for occupational illness including hearing loss, needlestick injuries and tuberculosis

Need to know what is a work-related incident or what exactly "restricted work behavior" means? Check out OSHA's letters of interpretation.

There are also injuries and illnesses that don't have to be recorded on your recordkeeping logs, and it's important to be aware of those as well. See our more detailed blog post on defining an OSHA recordable injury.

Are exposures to Coronavirus (COVID-19) OSHA recordable?

Yes. OSHA has recently provided guidance that while employers are exempt from recording incidents of employees contracting common colds and the flu in the workplace, any workplace contractions of Coronavirus MUST be recorded on the applicable recordkeeping logs IF it meets the following criteria:

  • The case is a confirmed case of COVID-19 (see the CDC's information on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19).
  • The case is work-related. If you're not clear on how OSHA defines what incidents should be considered work-related, we've got a helpful article on the subject.
  • The case involves one or more of the general recording criteria, such as a death, loss of consciousness, missed days away from work, restricted work activity or a job transfer, and medical treatment beyond first aid. 

For more information about recording exposures of COVID-19 in the workplace, see our detailed article.

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What are the OSHA Recordkeeping Logs?

There are three types of OSHA recordkeeping logs, the OSHA Form 301, 300, and 300A.  We have described each log and its requirements below.  Organizations covered under OSHA must complete these recordkeeping logs for all work-related OSHA recordable injuries and illnesses.

OSHA Form 301

OSHA Form 301 The OSHA 301 is an Injury and Illness Incident Report form, which must be filled out when a recordable work-related injury or illness occurs.  According to OSHA regulations, the 301 log must include details of the incident, including the extent and severity of an injury or illness, employee information, and medical information.

Within seven days after receiving information about an incident, employers are required to fill out this form (though an employer may use an equivalent form). It also must be kept on file for five years following the year during which the injury or illness happened.

 

 

OSHA Form 300

OSHA Form 300 The OSHA 300 log is an incident summary describing the who, what, when of work-related incidents that occur throughout the year for each work location.  Employers are required to complete and maintain an OSHA 300 log for each workplace location ("establishment").  The Occupational Safety and Health Administration (OSHA) regulations specify what type of workplace incidents employers must include on the OSHA 300 log.

According to OSHA regulations, the 300 log must include details of the incident, including the employee information, date of incident, and number of missed or restricted work days due to the incident. Employers are required to complete and maintain an OSHA 300 log for the year, accompanying the various 301 logs filed for each individual incident.  Organizations inspected by OSHA are required to produce a copy of their log upon request.

Sometimes during the course of an incident investigation, new information may come to light and an incident that was once thought to be OSHA recordable is no longer OSHA recordable. In these cases, OSHA requires organizations to redline the incident on the OSHA 300 log.  For more about redlining check out our redlining blog post.

OSHA Form 300A

OSHA Form 300A

The OSHA 300A log is an annual summary of all OSHA recordable incidents at each business location. The OSHA 300A log of the previous year's incidents must be posted for employees to view at each jobsite from February 1 to April 30.

OSHA requires that specific information be provided to employees on this log, including the total number of OSHA recordable incidents, the total number of hours worked, the total number of missed and restricted days, injury and illness types, and identifying company data.

Please see our detailed blog post on the OSHA 300A for more information.

Submitting Electronically to OSHA

If you are an establishment with more than 20 employees covered under the OSHA recordkeeping requirements, you need to submit your OSHA 300A information electronically to OSHA using their injury tracking application (ITA).

Establishments currently have until July 1st of the following year to submit their 300A information to OSHA for the previous year. While OSHA's electronic submissions are under potential revision (See below) the 300A electronic submission appears here to stay.

For more detailed guidance on how to use the Injury Tracking Application see our ITA guide.

OSHA electronic recordkeeping final rule

OSHA Changes to the New Recordkeeping Rule

In May of 2016, the Occupational Safety and Health Administration (OSHA) issued a final rule “Improve Tracking of Workplace Injuries and Illnesses” to revise its recording and reporting occupational injuries and illnesses regulation.

This ruling, which became effective on January 1, 2017, requires establishments with 250 or more employees, as well as establishments with 20 or more employees in high-risk industries, to electronically submit their 300A Form data to OSHA on an annual basis using the agency’s Injury Tracking Application (ITA).

On January 24, 2019, OSHA announced they had published a new final rule to Protect Privacy of Workers, which rescinds the agency's previous requirement for establishments with 250 or more employees to electronically submit Forms 300 and 301.  See our detailed blog post on  OSHA electronic recordkeeping changes for the details of this new NPRM.

Recording Injuries of Temporary Workers

There is much confusion surrounding how employers should be reporting to the Occupational Safety and Health Administration (OSHA) any injuries involving temporary workers. Many organizations either don't think they need to record these incidents or they aren't aggressive enough in letting workers know that they should be reported. In fact, a Washington State Department of Labor & Industries study found that only one-third of employers enter injuries from temporary workers into their OSHA logs. Unfortunately, this leads to situations in which temporary employees are not provided the same protection as permanent staff members.

OSHA has an entire website dedicated to issues that affect temporary workers. They recommend that staffing agencies and host employers work out in their contract which OSHA responsibilities they will handle, such as compliance and recordkeeping responsibilities.

This way, there is no confusion about who should fill out OSHA 301 Incident Report Forms in the event that one of these employees is injured on the job. While both organizations would be required to submit OSHA's Log of Work-Related Injuries and Illnesses (Form 300) if they have more than ten employees, only one would have to submit the incident form, depending on the terms of their service contract.

What is TCIR rate?

Total Case Incident Rate (or TCIR) is used to calculate the frequency of workplace injuries and illnesses and utilizes the data from the OSHA recordkeeping logs.   You can use TCIR to compare your rate to other organizations in your IndustrySafe.

Learn more about the TCIR Rate here.

Organizations can use Vector EHS Management Software's Incidents Module to assist with completing OSHA recordkeeping information and to achieve OSHA recordkeeping compliance.  Vector EHS can also calculate rate reporting to help you improve safety and reduce injuries and illnesses.  Contact us for more information.

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