Injury and illness recordkeeping

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OSHA forms

OSHA has three forms for recording injuries and illnesses: Form 300, 300A and 301. Form 300 is an annual log of work-related injuries and illnesses, and each entry must have a corresponding Form 301 report. Employers must record injuries and illnesses on the forms within seven calendar days of learning that they occurred.

Form 300A is a yearly summary of work-related injuries and illnesses. Employers must post a copy of this form “in a conspicuous place or places where notices to employees are customarily posted” by Feb. 1 of the following year (Feb. 1, 2021, for 2020 Form 300A, for example). That copy must remain posted until at least April 30.

Some establishments are required to send 300A information to OSHA electronically by March 2 of the following year. These include establishments with 250 or more employees as well as those with 20 to 249 employees in certain “high-hazard” industries.

What is a ‘recordable’?

Determining which injuries and illnesses are considered recordable, or ones that employers should enter on an OSHA log, can be another source of confusion.

Rothrock said some employers might think any injury or illness involving a workers’ compensation claim should be logged, but that’s not always the case.

According to OSHA, recordable injuries and illnesses are those that are work-related and result in death, days away from work, restricted work or transfer to another job (e.g., light duty), medical treatment “beyond first aid,” or loss of consciousness. Also required to be logged: any “significant” injury or illness diagnosed by a physician or other licensed health care professional – even if it doesn’t result in any of the above outcomes.

As examples, OSHA refers to work-related cases of cancer, fractured or cracked bones, and punctured eardrums under 1904.7(b)(7). Also, employers must record the following conditions if they are work-related:

• Needlestick injuries or a cut from a sharp object that is contaminated with another person’s blood or other potentially infectious material
• Any case requiring the medical removal of an employee under an OSHA standard (e.g., lead, cadmium and benzene standards)
• A tuberculosis infection diagnosed by a physician or licensed health care professional or via a positive skin test
• An employee hearing test or audiogram that reveals a “standard threshold shift” in one or both ears

OSHA provides its definition of types of “first aid” under 1904.7(b)(5)(ii). These include the use of nonprescription or nonprescription-strength medicine and the use of wound coverings such as bandages.

Rothrock recommends that employers print out or electronically bookmark OSHA’s definitions of first aid as a reference guide.

Work-relatedness and record retention

Understanding what is “work-related” can prove to be one of the more confounding topics, in large part because of, again, the number of possible scenarios.

Under 1904.5(b)(2), the OSHA standard has a table that features some general scenarios when an injury or illness is not considered work-related. An example is one that occurs “solely” because of an employee’s “personal task” at an establishment, unrelated to employment and outside of assigned work hours (e.g., a post-shift smoke break).

“It can be challenging when determining if an incident is considered to be work-related, since it can be based on a variety of factors of the work environment,” Rothrock said.

Gizzi and Rothrock highlighted one resource on OSHA’s website: a repository of Q&As. By typing in the key words “parking lot,” the website yields the following result, among others, from the agency’s e-correspondence:

Another area where organizations can go wrong, Tilton said, is not understanding OSHA’s requirement to retain injury and illness records for five years.

“It happens more than you think,” he said. “It’s something that happens to the biggest and the best (organizations).”

Employers also need to update past OSHA 300 logs during that five-year period if, for example, an employee’s time away from work goes from one year to the next. In this case, OSHA requires a company to record the injury or illness only once, so it would go on the prior year’s log. OSHA allows employers to cap the days away from work at 180 calendar days, under 1904.7(b)(3)(vii).

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