The Occupational Safety and Health Administration (OSHA) recordkeeping regulation requires employers with 10 or more employees in certain industries to routinely maintain “OSHA Logs.” To identify if your industry requires you to prepare and maintain OSHA logs, you can reference the full list of exempt industries here. These logs are used to record serious occupational injuries and illnesses. Maintaining accurate OSHA Logs is vital for all stakeholders when evaluating workplace safety, understanding hazards and risks, and determining the implementation of controls to reduce or eliminate hazards.
OSHA Logs consist of three separate documents:
- OSHA Form 300: Log of Work-Related Injuries and Illnesses
- OSHA Form 300A: Summary of Work-Related Injuries and Illnesses
- OSHA Form 301: Injury and Illness Incident Report
Applicable employers must maintain at least five years’ worth of each of these documents, as OSHA may request to review injury and illness records during facility inspections.
OSHA has developed a step-by-step guidance document to assist with the completion of the OSHA 300 logs, which can be found here.
Important 2022 Deadlines
The OSHA Form 300A Summary of Work-Related Injuries and Illnesses for the previous calendar year must be posted in a conspicuous location in the facility from February 1 to April 30 each year.
Along with the paper logs, the OSHA Form 300A Summary of Work-Related Injuries and Illnesses for the previous calendar year must be electronically reported through OSHA’s Injury Tracking Application by March 2 for applicable facilities (see information for applicability below).
What Injuries Need to be Recorded?
OSHA has outlined specific criteria for injuries that should be recorded on the OSHA 300 logs:
- 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; hearing loss; and tuberculosis.
All work-related injuries or illnesses should be recorded on the facility’s OSHA 300 log within seven days of the employer receiving notification of the incident. OSHA has outlined all general recording requirements in 29 CFR 1904.7.
In addition to logging the information, note that serious injuries meeting set criteria must also be called into OSHA at the time of the incident. Employers should regularly review their logs to ensure that any required reporting was not missed.
With OSHA’s updated recordkeeping rule, the list of severe injuries that employers must report to OSHA has expanded. For example, all work-related fatalities must be reported within 8 hours. Similarly, all work-related inpatient hospitalizations, amputations, and losses of an eye must be reported within 24 hours.
Electronic Submission of Injury and Illness Records to OSHA
Under the updated Final Rule that was made effective February 25, 2019, many facilities must electronically report their OSHA Form 300A: Summary of Work-Related Injuries and Illnesses to the OSHA Injury Tracking Application (ITA). Facilities that employ 250 or more employees that are required to maintain OSHA logs, and facilities that employ 20-249 employees that are classified as industries that have historically high injury rates, must electronically submit their OSHA Form 300A information. The full list of applicable industries can be found here.
In order to report your facility’s OSHA Form 300A information, visit the OSHA ITA website and follow the prompts for launching the Injury Tracking Application. If this is your first time reporting your facility’s OSHA Form 300A information, you will need to create an account to enter the facility’s information. You will need the establishment name, NAICS industry code, and the completed OSHA Form 300A for the previous year to complete the submission.
Potential Amendment to OSHA’s Recordkeeping Regulation
OSHA proposes to amend its recordkeeping regulation to restore the requirement of electronically submitted OSHA Form 300s (Log of Work-Related Injuries and Illnesses) and OSHA Form 301s (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep annual injury and illness records. Likewise, OSHA State Plan states will be required to follow suit. Under the current regulation, these establishments are only required to electronically submit information from the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses) annually.
COVID-19 and OSHA Recordkeeping
Under OSHA’s recordkeeping requirements, COVID-19 is a recordable illness, and thus employers are responsible for recording cases of COVID-19 if:
- The case is a confirmed case of COVID-19, as defined by the Centers for Disease Control and Prevention (CDC);
- The case is work-related as defined by 29 CFR 1904.5; and
- The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7.
On May 19, 2020, OSHA provided an updated guidance document to assist with determining if an employee’s positive COVID-19 case would be recordable on an employer’s OSHA logs. The below flow chart has been developed from the information in this guidance document to assist with the determination of work-relatedness.
If a COIVD-19 case is determined to be work-related, the incident would need to be recorded as a “Respiratory Condition.” If the employee requests that their name not be entered on the log, the case must be treated as a privacy case, as specified by 29 CFR 1904.29(b)(7)(VI).
If you have any issues determining an injury’s recordability or regarding your facility’s OSHA 300 logs, consult OSHA’s many recordkeeping resources or contact U.S. Compliance to assist with any recordkeeping questions or concerns.