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The Ultimate OSHA Recordkeeping Guide

Posted by admin on August 10, 2018
   

When it comes to OSHA recordkeeping there are always questions regarding the requirements and in and outs. IndustrySafe is here to help. We put together this page with critical information that’s easy to digest to assist you answer key questions about OSHA recordkeeping.

  • Who is required to complete OSHA recordkeeping ?
  • What is an OSHA Recordable Incident?
  • What are the recordkeeping logs ?
  • Do I have to submit electronically to OSHA ? 
  • What are the continued changes in rulemaking from OSHA for electronic submissions? 
  • What does TCIR Rate have to do with it?

Is my company required to complete OSHA recordkeeping?

Organizations in high risk industries with more than 10 employees are required by the Occupational Safety and Health Administration (OSHA) to track work-related employee injuries and illnesses according to OSHA recordkeeping requirements.  Organizations covered under OSHA must complete three recordkeeping logs for all work-related OSHA recordable injury and illnesses.

If you have 10 or fewer employees - temporary and contract workers included - or if you are part of a low-hazard industry that has been exempt according to your company's NAICs code, you don't have to keep OSHA injuries and illness records. 

However all organizations covered under OSHA have to comply with OSHA Reporting requirements which requires you to report directly to OSHA if a fatality, in-patient hospitalization, amputation, or loss of an eye occurs at your establishment due to a work-related incident.

Organizations in a few high risk industries such as  railroading or mining are not covered under OSHA regulations but are required to complete injury and illness reporting requirements to the appropriate regulatory agencies such as the Mine Safety and Health Administration (MSHA) or the Federal Railroad Administration (FRA).

What is an OSHA Recordable Injury ?

An OSHA recordable injury has to be work-related and result in any of the following circumstances:

  • Death
  • Loss of consciousness
  • Days away from work
  • Restricted work activity or job transfer
  • Medical treatment beyond first aid
  • Additional criteria for occupational illness including hearing loss, needlestick injuries and tuberculosis

Need to know what is a work-related incident or what exactly does medical treatment beyond first aid mean to OSHA ? Check out OSHA's letters of interpretation and also our more detailed blog post on defining an OSHA recordable injury .

What are the OSHA Recordkeeping Logs ?

There are three OSHA recordkeeping logs, the OSHA Form 301, 300, and 300A.  We have described each log and their requirements below.  Organizations covered under OSHA must complete these recordkeeping logs for all work-related OSHA recordable injury and illnesses.

OSHA 301

The OSHA 301 is an Injury and Illness Incident Report form, which must be filled out when a recordable work-related injury or illness occurs.  According to OSHA regulations, the 301 log must include details of the incident, including the extent and severity of an injury or illness, employee information and medical information.  

Within seven days after receiving information about an incident, employers are required to fill out this form (though employee may use an equivalent form). It also must be kept on file for five years following the year during which the injury or illness happened.

OSHA Form 300

The OSHA 300 log is an incident summary describing the who, what, when of work-related incidents that occur throughout the year for each work location.  Employers are required to complete and maintain an OSHA 300 log for each workplace location ("establishment").  The Occupational Safety and Health Administration (OSHA) regulations specify what type of workplace incidents employers must include on the OSHA 300 log.

According to OSHA regulations, the 300 log must include details of the incident, including the employee information, date of incident, and number of missed or restricted work days due to the incident. Employers are required to complete and maintain an OSHA 300 log for the year, accompanying the various 301 logs filed for each individual incident.  Organizations inspected by OSHA are required to produce a copy of their log upon request.

OSHA Form 300A 

he OSHA 300A log is an annual summary of all OSHA recordable incidents at each business location. The OSHA 300A log of the previous year's incidents must be posted for employees to view at each jobsite from February 1 to April 30.

OSHA requires specific information be provided to employees on this log, including the total number of OSHA recordable incidents, total number of hours worked, total number of missed and restricted days, injury and illness types, and identifying company data.

Please see our detailed blog post on the OSHA 300A for more information.

Submitting Electronically to OSHA

If you are an establishment with more than 20 employees covered under the OSHA recordkeeping requirements, you need to submit your OSHA 300A information electronically to OSHA using their injury tracking application (ITA).

Establishments currently have until July 1st of the following year to submit their 300A information to OSHA for the previous year.   While OSHA's electronic submissions are under potential revision (See below) the 300A electronic submission appears here to stay.

For more detailed guidance on how to use the Injury Tracking Application see our ITA detailed guidance.

OSHA Changes to the New Recordkeeping Rule

In May of 2016, the Occupational Safety and Health Administration (OSHA) issued a final rule “Improve Tracking of Workplace Injuries and Illnesses” to revise its recording and reporting occupational injuries and illnesses regulation.

This ruling, which became effective on January 1, 2017, requires establishments with 250 or more employees, as well as establishments with 20 or more employees in high risk industries, to electronically submit their 300A Form data to OSHA on an annual basis using the agency’s Injury Tracking Application (ITA).

 On July 30, 2018, OSHA published a Notice of Proposed Rulemaking (NPRM), which rescinds the agency's previous requirement for establishments with 250 or more employees to electronically submit Forms 300 and 301.  See our detailed blog post on  OSHA electronic recordkeeping changes for the details of this new NPRM.

What is TCIR rate ?

Total Case Incident Rate (or TCIR) is used to calculate  the frequency of work place injuries and illnesses  and utilizes the data from the OSHA recordkeeping logs.   You can use TCIR to compare your rate to other organizations in your industrysafe.

Learn more about TCIR Rate here.

Organizations can use IndustrySafe Safety Management Software Incidents Module to assist with completing OSHA recordkeeping information and to achieve OSHA recordkeeping compliance.  IndustrySafe can also calculate rate reporting to help you improve safety and reduce injuries and illnesses.  Contact us for more information.

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