Understanding OSHA Illness & Injury Recordkeeping Requirements

In 2003, the most current statistics available, occupational injury and illness rates declined once more to 5.0 cases per 100 workers, thanks in great part to continuing efforts by OSHA to identify and correct hazards in the workplace.  OSHA is able to recognize workplace hazards by thoroughly tracking workplace injuries, illnesses and deaths.  Stringent requirements have been in place for record keeping of work-related illnesses and injuries since 1971.  To remain compliant and help OSHA continue to reduce workplace accidents and illnesses, it is crucial that employers understand their record keeping responsibilities.

First, a company must know whether they are required to keep records of work-related accidents, injuries, and illnesses.  Small businesses with 10 or fewer employees are exempt unless they are selected by OSHA or the Bureau of Labor Statistics to be involved in a mandatory data collection.  Some low-hazard classified industries in the retail, service, finance, insurance and real estate sectors, are also exempt.   A full list is available at www.osha.gov.  However, when a worker is killed on the job, and/or three or more workers are hospitalized, all employers covered by OSHA, including those who are exempt for the above reasons, must report to the agency within eight hours.

Secondly, it is crucial to know that work-related is defined as an event or exposure in the work environment that caused or contributed to the condition.  Injuries and illnesses are reportable even if an employee has a pre-existing condition that was significantly aggravated by a situation that occurred in the work environment.

To accurately follow OSHA’s record keeping guidelines, companies must know how to identify which work-related illnesses or injuries are reportable.  Those that result in death, loss of consciousness, days away from work, restricted work activity, job transfer or medical treatment, beyond first aid, must be reported.  Furthermore, employers must report any significant work-related injury or illness that is diagnosed by a licensed health care professional including work-related cases involving cancer, chronic irreversible disease, a fractured bone or a punctured eardrum.  Visit www.osha.gov for a full list of criteria that also includes any needle stick injury or tuberculosis infection. 

Though companies are not required to routinely submit their incident reports, they are expected to vigilantly record them as OSHA conducts random site visits and could otherwise request them at anytime.  There are three key required forms:

1.                  Injury and Illness Report (Form 301) This form details the incident and must be filled out within seven calendar days of learning that a recordable work-related injury or illness has occurred.   It must be kept on file for five years following the year to which it pertains.

2.                  Log of Work-Related Injuries and Illnesses (Form 300) This form is a running list of all work-related injuries and illnesses.  Employers must keep a log for each worksite.

3.                  Summary of Work-Related Injuries and Illnesses (Form 300A) This form totals the injuries and illnesses for the year and must be visibly posted at the worksite February 1 through April 30 of the year following the year indicated in the form.

Employers must know that their employees have the right to review their injury and illness records and that listing a case on the log does not mean the employer violated an OSHA standard or was at fault.  All the appropriate forms and instructions for completing them are available at www.osha.gov.

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