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OSHA Recordkeeping: What You Need to Know and Do

For industries like construction and manufacturing with inherent safety risks, worker injuries can occur despite the best safety practices. OSHA has a set of rules and regulations for how injuries or illnesses should be investigated, documented and reported. While these are valuable to assess your safety and health needs, filling out OSHA reporting forms can sometimes be confusing.

Is your company clear on what constitutes a recordable injury or illness in these circumstances? It’s imperative you are.

Did you know? In Fiscal Year 2020, OSHA issued 1,292 citations for violations of standard 1904, Recording and Reporting Occupational Injuries and Illness. The purpose of this rule (Part 1904) is to require employers to record and report work-related fatalities, injuries and illnesses. 

Top 3 sections cited

  1. 1904.39(a)(2): Within twenty-four (24) hours after the in-patient hospitalization of one or more employees or an employee’s amputation or an employee’s loss of an eye, as a result of a work-related incident, you must report the in-patient hospitalization, amputation, or loss of an eye to OSHA – 602 citations
  2. 1904.40(a): When an authorized government representative asks for the records you keep under part 1904, you must provide copies of the records within 4 business hours – 120 citations
  3. 1904.29(a): Within eight (8) hours after the death of any employee as a result of a work-related incident, you must report the fatality to the Occupational Safety and Health Administration (OSHA), U.S. Department of Labor– 111 citations

OSHA Recordkeeping Purpose

The purpose of OSHA’s recordkeeping requirements is to help evaluate the safety of a workplace and to 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 as well as the employer in the implementation of their safety programs and procedures. It can serve to guide employers’ efforts in finding and eliminating workplace hazards.

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 injuriesmedical removalhearing loss; and tuberculosis.

The third bullet point notes that only treatment beyond first aid needs to be recorded. Which brings up the question of how OSHA defines first aid. In summary, it includes non-prescription medications, wound coverings, hot or cold therapy, non-rigid means of support such as wraps and back belts, eye patches, removing splinters, using finger guards and drinking fluids for heat stress. 

Who Needs to File OHSA Reports?

Per 1904.1(a)(1), if your company had 10 or fewer employees at all times during the last calendar year, you do not need to keep OSHA injury and illness records unless OSHA or the Bureau of Labor Statistics informs you in writing that you must keep records under § 1904.41 or § 1904.42. However, as required by § 1904.39, all employers covered by the OSH Act must report to OSHA any work-related incident that results in a fatality, the in-patient hospitalization of one or more employees, an employee amputation, or an employee loss of an eye.

Or according to 1904.1(a)(2), if your company had more than ten (10) employees at any time during the last calendar year, you must keep OSHA injury and illness records unless your establishment is classified as a partially exempt industry under § 1904.2.

What OSHA Reports are Required?

Employers must report 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. Details on how to report a fatality or severe injury.

In addition to reporting the fatality or serious injury, you must also keep a log of work-related injuries and illnesses. Any time a recordable incident occurs, you’ll need to record details about what happened and how it happened on the OSHA 300 Log. These incidents need to be recorded within seven calendar days.

There’s also a Summary of Work-Related Injuries and Illness, OSHA form 300A. This form is filed annually and summarizes all those incidents recorded on the form 300 log. 

There’s an excellent summary of how to complete form 300A at OSHA Forms for Recording Work-Related Injuries and Illnesses. You can also find all the forms in PDF fillable versions or in Microsoft Excel versions at Injury and Illness Recordkeeping Forms – 300, 300A, 301.