OSHA Recordkeeping Requirements and e-submission Guidelines

OSHA Recordkeeping requirements

What are OSHA’s record-keeping requirements?

OSHA recordkeeping requirements affect approximately 1.4 million businesses. Many employers with more than ten employees must record serious work-related injuries and illnesses with a few exceptions (listed below). Minor injuries requiring first aid only do not need to be recorded.

This information helps employers, workers, and OSHA evaluate the safety of a workplace, understand industry hazards, and implement worker protections. These requirements reduce and eliminate risks-preventing future workplace injuries and illnesses.

How does OSHA define first aid?

Osha Recordkeeping Requirments

OSHA has stringent definitions of first aid. First aid refers to medical attention that is usually administered immediately after the injury occurs and at the location where it happened. It often consists of a one-time, short-term treatment and requires little technology or training to administer.

First aid can include cleaning minor cuts, scrapes, or scratches; treating a minor burn; applying bandages and dressings; using non-prescription medicine; draining blisters; removing debris from the eyes; massage; and drinking fluids to relieve heat stress. OSHA’s revised recordkeeping rule, which went into effect January 1, 2002, does not require first aid cases to be documented.

Are there businesses that are exempt from the recordkeeping requirements?

Yes, low-hazard industries such as retail, finance, insurance, and real estate are exempt. Small businesses with less than ten employees are exempt from the recordkeeping rule only, not all OSHA requirements.

What are the OSHA forms for recordkeeping?

OSHA provides the following forms on their Injury and Illness Recordkeeping Forms website page:

  • OSHA Form 300 Log of Injuries and Illnesses
  • OSHA Form 300A – Summary Form. Employers must post the annual summary Form 300A from February 1st to April 30th of the following year. This information will be used in the e-submission to OSHA. Note: Even if your facility has had ZERO OSHA recordables, you are still required to post the OSHA 300A Form and submit it electronically to OSHA.
  • OSHA Form 301 Supplemental Information covers the granular details of the accidents.

Per OSHA, it guarantees that employees and former employers have access to their individual OSHA 301 Forms. Employee representatives will be provided access to “the information about the case” section of the OSHA 301 Form in establishments where they represent employees.

Recordkeeping discrimination

Employers cannot discriminate against employees for reporting an illness or injury. OSHA requires employers to:

  1. Establish a procedure for employees to report injuries and illnesses
  2. Tell and train the employees how to report an injury or illness

However, if an employee violates an established safety practice and has been trained, the employer can utilize the progressive disciplinary system. According to SHRM, The system uses graduated steps for dealing with problems related to an employee’s conduct or performance that do not meet clearly defined standards and policies. The ultimate objective of progressive discipline is to help employees correct conduct problems and resolve performance issues in the earliest stages.

OSHA recordkeeping facts

OSHA Recordkeeping Requirements and e-submission guidelines

OSHA requires documentation and recordkeeping to include work-related injury or illness resulting in:

  • Death
  • Days Away from Work
  • Restricted Work or Transfer to Another Job
  • Medical Treatment Beyond First Aid
  • Loss of Consciousness
  • Diagnosis of a Significant Injury or Illness by a Physician or Licensed Healthcare Professional

Employers must also report any work-related fatalities to OSHA within 8 hours, including heart attacks.

Preexisting Condition: OHSA also requires a significant degree of aggravation before a preexisting injury or illness is considered work-related. It is up to the company to determine if or how a work-related case occurred. We strongly recommend that you defer to a health care professional diagnosis.

Employee Privacy: OSHA prohibits employers from entering an individual’s name on OSHA Form 300 for certain types of injuries or illnesses (sexual assault, HIV infection, mental illness, etc.) and allows employers not to describe the nature of sensitive injuries where the employee’s identity would be known. The employer/manager would enter “privacy” instead of entering the employee’s name and adding the details.  These are filed and locked in a secure environment.

Light duty or restricted work cases

Light duty or restricted word status often occurs when someone is hurt.  OSHA requires employers to record cases when the injured or ill employee is restricted from “routine job functions,” defined as work activities the employee regularly performs at least once weekly.

For example, if an office manager lifted a heavy box and strained her back, her doctor may have put a restriction on how much she could lift.  Lifting is not a common or routine job function, so she would not be placed on light duty. However, a warehouse worker who falls to the same injury would be placed on light duty because the restriction affects her routine job functions.

Employers are required to count calendars, not scheduled workdays.

How do I determine if a case is OSHA recordable or not?

First, determine if it was work-related. Further defined by OSHA, the employer must consider an injury or illness work-related if an event or exposure in the work environment caused or significantly aggravated a pre-existing injury or illness.

Next, did the injury occur during travel, and what is the definition of travel status? So basically, injuries and illnesses that occur while an employee is on travel status are work-related if, at the time of the injury or illness, the employee was engaged in work activities “in the interest of the employer.” Exceptions include time in a hotel, aka home away from home, and any additional travel for personal reasons during business travel.

How can you determine if the injury or illness is a new case?  OHSA defines a new case if the employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body or previously experienced a documented injury or illness of the same kind that involved the same part of the body but had fully recovered. All signs and symptoms had disappeared from the previous injury or illness. Then, an event or exposure in the work environment caused the signs or systems to reappear.

How does electronic submission work?

The Injury Tracking Application (ITA) is accessible from the ITA launch page. You can provide the Agency with your OSHA Form 300A information. The date by which certain employers must submit to OSHA the data from their completed Form 300A is March 2nd, after the calendar year covered by the form.

Employers must submit these reports to OSHA:

  • By telephone at 1-800-321-OSHA (6742)
  • By calling or visiting the nearest area office during regular business hours; or

through an online form.

  • If State OSHA Plan State, follow those reporting guidelines.

For the latest updates, check the OSHA website or OSHA’s Email Newsletter QuickTakes.

Catamount Consulting can help with OSHA recordkeeping requirements and compliance.

Catamount Consulting provides mining, construction, and general industry operators with professional safety services, consultation, and compliance strategies with the highest regard for quality and employee safety.

Click here to view the webinar and learn more about OSHA recordkeeping best practices and implementation.

Special thanks to our presenter, Joe Keenan, MBA, CSP from Catamount Consulting.


References: https://www.osha.gov/recordkeeping and SHRM