OSHA Recordkeeping Toolkit

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Contact: Rob Matuga
(202) 266-8507
rmatuga@nahb.org

Insurance carriers and government regulatory agencies require various work-related accident and injury reports. Under the OSHA recordkeeping regulation (29 CFR 1904), covered employers must prepare and maintain records of serious occupational injuries and illnesses using the OSHA Recordkeeping Forms.

Am I required to prepare and maintain records

Employers with more than 10 employees and whose establishments are not classified as a partially exempt industry must record work-related injuries and illnesses using OSHA forms 300 (log of injuries), 300A (summary of injuries) and 301 (incident report). Employers are not responsible for reporting on subcontractors. Subcontractors are considered separate employers by OSHA and must maintain their own OSHA records.

When am I required to post injury and illness summaries

Employers who are required to prepare and maintain accurate records must post Form 300A Summary only — not the Log — by Feb. 1 of the year following the year covered by the form and keep it posted until April 30 of that year. Form 300A should be displayed in a common area where notices to employees are usually posted and must be signed and certified by a company executive. If a company recorded no injuries or illnesses, the employer must enter the number zero on the total line. In addition, employers must keep and maintain the accurate Log and Summary for five years following the year to which they pertain.

What is recordable under OSHAs recordkeeping regulation?
  • Covered employers must record all work-related fatalities.
  • Covered employers must record all work-related injuries and illnesses that result in days away from work, restricted work or transfer to another job, loss of consciousness or medical treatment beyond first aid (see OSHA’s definition of first aid).
  • In addition, employers must record significant work-related injuries or illnesses diagnoses by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
  • Injuries include cases such as a cut, fracture, sprain or amputation.
  • Illnesses include both acute and chronic illnesses such as a skin disease (i.e., contact dermatitis), respiratory disorder (i.e., occupational asthma, pneumoconiosis), or poisoning (i.e., lead poisoning, solvent intoxication).
  • OSHA’s definition of work-related injuries, illnesses and fatalities are those in which an event or exposure in the work environment either caused or contributed to the condition or significantly aggravated a pre-existing injury or illness.
What am I required to report

Employers are required to notify OSHA of work-related fatalities within eight hours, and work-related in-patient hospitalizations, amputations or losses of an eye within 24 hours.

Employers have three options for reporting these severe incidents to OSHA:

Previously, OSHA’s regulations required an employer to report only work-related fatalities and in-patient hospitalizations of three or more employees. Reporting single hospitalizations, amputations or loss of an eye was not required under the previous rule.

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