4.2 OSHA Recordkeeping & Injury Reporting (OSHA 300, 300A, 301)

OSHA Recordkeeping & Injury Reporting (29 CFR 1904)

Accurate recordkeeping is not just a paperwork exercise; it is a vital tool for analyzing workplace hazards and preventing future incidents. OSHA's recordkeeping standard (29 CFR 1904) dictates exactly what types of injuries and illnesses must be recorded, how they are recorded, and when severe incidents must be reported directly to OSHA. As an OHST, mastering these rules is essential for ensuring organizational compliance and maintaining accurate safety data.

The Three OSHA Recordkeeping Forms

Employers required to keep records must maintain three specific forms (or equivalents):

1. OSHA Form 300 (Log of Work-Related Injuries and Illnesses): This is a line-by-line log of every recordable injury or illness that occurs during the calendar year. It includes the employee's name, job title, date of injury, description of the injury/illness, and the outcome (e.g., days away from work, job transfer/restriction, or other recordable cases). This log must be kept confidential and is not posted publicly.
2. OSHA Form 300A (Summary of Work-Related Injuries and Illnesses): This is an annual summary of the data from the Form 300 log. It aggregates the total number of cases, days away/restricted, and injury types, without listing employee names. Critical rule: The Form 300A must be certified by a company executive and posted in a visible location in the workplace from February 1 to April 30 of the year following the year covered by the form.
3. OSHA Form 301 (Injury and Illness Incident Report): This form provides detailed information about each specific incident recorded on the Form 300. It asks questions about what the employee was doing before the incident, how the injury occurred, and the nature of the injury. A Form 301 (or an equivalent form like a detailed workers' compensation report that contains the same information) must be completed within 7 calendar days of receiving information that a recordable case occurred.

Determining Work-Relatedness

An injury or illness is considered work-related if an event or exposure in the work environment either caused or contributed to the resulting condition, or significantly aggravated a pre-existing injury or illness. The "work environment" includes the physical location and the equipment/materials used by the employee during the course of their work.

There are several exceptions to work-relatedness (e.g., injuries occurring while eating in the breakroom during normal break time, injuries resulting solely from voluntary participation in a wellness program, or injuries caused by an employee's personal tasks outside of assigned working hours). An OHST must carefully evaluate these exceptions when determining recordability.

Criteria for Recording (The "General Recording Criteria")

If an injury or illness is work-related, it must be recorded on the OSHA 300 log if it results in one or more of the following:

• Death: Must be recorded immediately.
• Days Away From Work (DAFW): If the employee cannot work any part of a day following the day of the injury. The day of the injury itself does not count.
• Restricted Work or Transfer to Another Job: If the employee is kept from performing one or more of their routine functions, or from working the full workday they would otherwise have been scheduled to work.
• Medical Treatment Beyond First Aid: This is often the trickiest criteria. OSHA clearly defines what constitutes "first aid." If the treatment goes beyond that list, it is recordable. For example, using a non-prescription medication at non-prescription strength is first aid. Using a prescription medication (even a single dose) is medical treatment. Closing a wound with steri-strips is first aid; closing it with sutures or staples is medical treatment.
• Loss of Consciousness: Any time a worker loses consciousness due to a work-related event, it is recordable, regardless of duration.
• Significant Injury or Illness Diagnosed by a PLHCP: (Physician or Other Licensed Health Care Professional). Examples include work-related cancer, chronic irreversible diseases, or fractured bones, even if they don't immediately result in days away or medical treatment.

Specific Recording Criteria

OSHA also has specific criteria for recording certain types of conditions, regardless of the general criteria above. These include:

• Needlestick and Sharps Injuries: All work-related needlestick injuries and cuts from sharp objects contaminated with another person's blood or other potentially infectious materials (OPIM) must be recorded.
• Hearing Loss: A Standard Threshold Shift (STS) in hearing (10 dB or more) that brings the overall hearing level to 25 dB or more above audiometric zero in the same ear must be recorded, if determined to be work-related.
• Medical Removal: If an employee is medically removed under the medical surveillance requirements of an OSHA standard (e.g., lead or asbestos).
• Tuberculosis: If an employee is occupationally exposed to a known case of active TB and subsequently develops a TB infection.

Severe Injury Reporting (Immediate Notification)

In addition to annual recordkeeping, OSHA requires immediate reporting of severe incidents. These reports must be made directly to OSHA (via phone to the local area office, the 24-hour hotline, or the online reporting portal).

These timeframes begin as soon as the employer (or any management representative) learns of the incident and determines it is work-related and meets the reporting criteria. Failing to report these severe incidents within the required timeframe frequently results in significant citations.