The Occupational Safety and Health Administration (OSHA) requires most employers to prepare and maintain records of job-related injuries and illnesses. This data serves as an important resource for those evaluating job safety. 

This requirement aids in identifying specific industry hazards and is intended to improve overall workplace safety. However, the recordkeeping process can be confusing and difficult to navigate. 

What are the forms?

Who is responsible for keeping records? Employers in a low-risk industry or with fewer than 11 employees are exempt. What work-related illnesses and injuries must be recorded? Minor injuries that only require first aid do not need to be recorded. OSHA’s recordkeeping regulation provides a list of exempt industries and clarifies what is considered first aid. Consult these lists when deciding which injuries to record. 

There are three OSHA forms: 300, 300A and 301. The Injury Illness and Incident Report, or OSHA 301, is the initial form to capture the details of the incident and illness or injury. Organizations can use an alternate one, but it must contain the same information found on this form. 

Most information from OSHA 301 needs to be transferred to the Log of Work-Related Injuries and Illnesses, or OSHA 300. This form is used to classify injuries and illnesses as well as indicate the extent of each.

On OSHA 300A, Summary of Work-­Related Injuries and Illnesses, employers record totals for the year in each category, including the type of case, type of injury or illness, and days away or restricted days. 

After an injury or illness occurs, employers have seven days to complete form 301 or equivalent and add the incident to form 300. Each one must be kept for five years. However, only form 300 needs to be updated if changes occur to the injury or illness (i.e., number of days away). These documents should be kept in a central location or electronically. 

A different log must be used for each establishment, which is defined as a location operating for one year or more. When keeping location records, the employer must be able to meet the timelines for delivering them to those parties covered in the regulations. 

When OSHA or another government entity requests documents, employers are required to produce them within four hours. The next business day is adequate for employees, former employees, the authorized employee representative and personal employee representative. The regulations can be referenced at any time to determine what private information can be withheld. Form 300A has no private information and is required to be posted from Feb. 1 to April 30 each year. It must be certified by a company executive, which must be the owner, officer of the corporation, highest-­ranking company official at that establishment or their immediate supervisor.

In 2016, OSHA established rules that require employers to submit OSHA 301, 300 and 300A electronically, depending on size. Subsequent revisions to the rule eliminated much of this. Three employer categories were identified as having submission requirements. Employers with 20–249 employees listed in Appendix A need only submit their 300A annually. The construction industry is included. 

Employers with 250 or more employees, whether in Appendix A or simply covered by the rule in general, must also submit form 300A. A limited number of industries covered in Appendix B must submit their 301, 300 and 300A annually if they have 100 or more employees. Construction is not currently listed in Appendix B. Submissions are due by March 2 each year. 

Unlike electronic submission and the limitations on maintaining records, some injury and illness requirements apply to every employer no matter the size or industry. All job-related fatalities must be reported to OSHA within eight hours of management becoming aware of them. 

Additionally, employers have 24 hours to report an in-patient hospitalization of one or more employees, an amputation or loss of an eye resulting from a work-related incident. These reports can be made by phone or in person at the nearest OSHA Area Office or by telephone to OSHA’s toll-free number: 1.800.321.OSHA (1.800.321.6742). OSHA also has an electronic submission option at www.osha.gov. 

Common mistakes

Common mistakes employers make during this process include failing to appropriately classify injuries and illnesses, improperly documenting sufficient detail in records, not keeping OSHA 300 logs up to date, not reporting minor injuries, neglecting to maintain records for the required amount of time, and inadequately or not training workers tasked with recordkeeping duties. 

Making these errors can result in inaccurate assessments of injury or illness severity, skewed statistics and underreporting of minor injuries. Records that fail to capture enough information also make it challenging to analyze trends and identify or correct hazardous conditions. Therefore, it is imperative to closely follow regulations and adhere to all OSHA recordkeeping requirements.

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