Most employers are required to prepare and maintain records of job-related injuries and illnesses to comply with OSHA regulations. Recordkeeping is also a valuable resource to evaluate workplace safety by identifying specific industry hazards and how to abate them. However, there can be intricacies with recordkeeping that make compliance and understanding requirements challenging.

There are very specific guidelines for who must keep records and what work-related illnesses and injuries must be recorded. Employers with fewer than 11 employees or in a low-risk industry are exempt. Minor injuries that only require first aid do not need to be recorded. OSHA regulations provide a list of exempt industries and clarify what is or isn’t considered first aid. Be sure to review these lists to decide what injuries to record.

Three important forms to know

One common recordkeeping challenge is the forms themselves. Responsible parties must know when and how to use them. This means employers must know what information is needed on each, the location and timelines for storage and any requirements for posting or submitting. There are three OSHA forms: 300, 300A and 301. 

The Injury and Illness Incident Report, or OSHA 301, is the first form to capture the details of a recordable incidence of illness or injury. Employers may use an alternate form, but it must contain all the information included on the 301 form. Many state worker compensation forms meet this requirement. 

A lot of the information in the 301 form must be transferred to the Log of Work-­Related Injuries and Illnesses, or OSHA 300. This is used to classify injuries and illnesses and requires a denotation for the extent and severity of each case. 

OSHA 300A, Summary of Work-Related Injuries and Illnesses, includes the yearly totals for each category and each type of case, type of injury or illness, and days away or restricted days. 

Keeping the records

After an incident occurs, employers have seven calendar days to complete the 301 form or equivalent. Then it needs to be added to the 300 form. All forms need to be kept for five years, but only the 300 must be updated if changes occur in the injury or illness, such as number of days away. These records can be kept at a central location or electronically. However, a different log must be used for each establishment operating for a year or more. 

Wherever records are kept, employers must be able to meet the timelines for delivering them to those parties covered under the regulations. For a government representative (i.e., OSHA), the timeline is four hours. If the request comes from employees, former employees, an authorized employee representative or personal employee representative, the next business day is fine. Reference the regulations to determine what privacy information can be withheld when providing forms to others. 

The 300A form has no privacy information and is required to be posted from Feb. 1 to April 30 each year. It must be certified by a company executive such as the owner, an officer of the corporation, highest ranking company official at that establishment, or their immediate supervisor.

In 2016, OSHA promulgated rules requiring employers to submit the OSHA 301, 300 and 300A forms electronically, depending on size. Subsequent revisions to the rule eliminated much of this. Currently, only the 300A form must be submitted electronically on an annual basis. This applies to employers required to keep records per the rule with 250 or more employees and employers with 20 to 249 employees listed as a designated industry in the rule. The submission must occur by March 2 of each year. 

Beginning in 2024, employers with 100 or more employees and operating in high-hazard industries are required to electronically submit data from all three forms every year. 

Electrical and line work fall into that category per Appendix B to Subpart E of 29 CFR Part 1904. These requirements are separate from OSHA’s specific safety standards addressing electrical hazards, electrocution, fires and explosions.

Contrary to the electronic submission and limitations on maintaining records, there are injury and illness requirements that apply to every employer regardless of size or industry. 

All work-related fatalities must be reported to OSHA within eight hours of management becoming aware of it. Employers have 24 hours to report an inpatient hospitalization of one or more employees, amputation or loss of an eye resulting from a work-related incident. 

stock.adobe.com / hvostik16