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The statistics on OSHA recordkeeping citations aren’t getting any better. Last year, we reported 505 citations and $1.99 million in penalties for the twelve months ending in September 2022. This year, that number has jumped to 673 citations and over $2.5 million in penalties as of September 2023.
From this, you can tell that reviewing OSHA recordkeeping requirements must be an annual ritual with serious deadlines. But it isn’t something to do once a year and forget about. It’s a regular everyday requirement. But why? And, as importantly, how?
This article reviews the why, the how and all the requirements.
The Why Behind OSHA Recordkeeping
The why behind OSHA’s recordkeeping requirements boils down to, first, understanding the purpose of recordkeeping and, second, coming to grips with the citations and penalties imposed on those who don’t follow OSHA’s requirements.
The Purpose of OSHA Recordkeeping
The purpose is not to find fault, although that does happen. Instead, the purpose of OSHA’s recordkeeping requirements is to help evaluate workplace safety and understand industry hazards. From this information, worker protections, including training, can be provided to prevent future injuries and illnesses.
The data compiled is not only for OSHA’s use but for the use of workers to evaluate a workplace and the employer’s efforts in implementing their safety programs and procedures. The bottom line is that diligent recordkeeping can guide employers’ efforts to find and eliminate workplace hazards.
OSHA Citations and Penalties
OSHA citations for violations, including recordkeeping violations, can be costly. The minimum penalty for 2023, with 2024 adjustments pending announcement, is $15,625 per violation and another $15,625 per day for failure to abate—a willful or repeated violation results in an astonishing $156,259 per violation. See our article on OSHA Citations: Prevention vs. Penalty for more insight.
Digging deeper behind these citations and penalties, it’s wise to note that OSHA has a six-month window to cite employers for failure to record an incident. The clock begins running immediately after the injury or illness, even though the OSHA inspection may not happen for months afterward.
For this reason, OSHA is issuing recordkeeping citations as quickly as possible to avoid the citation limitation. Once that initial recordkeeping citation is on the record, additional citations can be listed as repeat violations, resulting in more and much higher penalties. Given that, keeping on top of all recordkeeping requirements is essential.
The How of OSHA Recordkeeping
So, how do you keep on top of OSHA recordkeeping requirements? Here’s what you need to know.
Who Needs to File OSHA Reports?
Many employers with more than ten employees must keep a record of serious work-related injuries and illnesses. First-aid types of injuries don’t need to be recorded. There are also requirements for annual summary reporting. Employers with fewer than ten employees and those in low-risk industries are exempt from recordkeeping requirements.
What is an OSHA Recordable Injury or Illness?
Here is OSHA’s definition of a recordable injury or illness:
- Any work-related fatality.
- Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work or transfer to another job.
- Any work-related injury or illness requiring medical treatment beyond first aid.
- Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth and punctured eardrums.
- There are also special recording criteria for work-related cases involving needlesticks and sharps injuries, medical removal from the workplace, hearing loss and tuberculosis.
OHSA defines “beyond first aid” as non-prescription medications, wound coverings, hot or cold therapy, non-rigid support such as wraps and back belts, eye patches, removing splinters, using finger guards and drinking fluids for heat stress. For more information, look at OSHA’s detailed first aid definition.
What OSHA Reports are Required?
Serious event reports are required for any work-related fatality within eight hours. Work-related amputations, inpatient hospitalizations and the loss of any eye must be reported within 24 hours of learning of the incident.
In addition to the serious event report, you must log work-related injuries and illnesses. That’s recorded on OSHA Form 300. Any time an incident occurs, you’ll need to record details about what happened and how it happened. These incidents need to be recorded within seven calendar days. You can find more information in our article, OSHA 300 Log.
There’s also a Summary of Work-Related Injuries and Illness, OSHA Form 300A. This form is filed annually and must consider all incidents recorded on the Form 300 log. Learn more about Form 300A at OSHA Forms for Recording Work-Related Injuries and Illnesses. All the forms are available in PDF fillable versions or Microsoft Excel versions at Injury and Illness Recordkeeping Forms – 300, 300A, 301.
How to File an OSHA Report
Call the nearest OSHA office or the 24-hour hotline at 1-800-321-6742 for serious event incidents. You can also report online using the Serious Event Reporting Online Form.
The serious injury and illness report is OSHA form 301. The annual OSHA form 300A can be reported online via the Injury Tracking Application. This requires setting up an account before filing your report.
When are the Annual OSHA Reports Due?
As noted above, there are immediate filing requirements for injuries or illnesses. The annual reporting requirements vary by the size of the organization.
Establishments with 20-249 employees in high-risk industries, which includes manufacturing and construction, must submit information from their 2023 Form 300A by March 2, 2024. Establishments with 250 or more employees in industries covered by the recordkeeping regulation must also submit information by the same date.
Note that a further requirement is effective January 1, 2024, that requires all establishments with 100 or more employees in certain high-hazard industries must electronically submit Form 300-Log, Form 30- Injury and Illness Incident Report in addition to the Form 300A-Summary of Work-Related Injuries and Illnesses.
Paper copies of Form 300A must be posted in the workplace from February 1 through April 30 so all employees can review the complete list of injuries and illnesses.
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