February 1 Deadline Fast Approaching
Under the Occupational Safety and Health Administration’s (OSHA) Recordkeeping regulation (29 CFR 1904), covered employers are required to prepare and maintain records of serious occupational injuries and illnesses, using the OSHA 300 Log. OSHA also requires employers to post an annual summary using OSHA’s Form 300A, no later than February 1 of each year.
Are You a Covered Employer?
Most employers are covered with two notable exceptions: (1) employers with less than 10 employees and (2) employers operating in certain “low hazard” industries. Here is a list of industries exempt from the reporting requirements.
I’m Covered, What Am I Supposed to Do?
Covered employers must complete and post an OSHA Form 300A (Annual Summary) no later than February 1 of the year following the year covered by the records and keep the posting in place until April 30. In other words, by February 1, 2016, you must post the OSHA Form 300A for injuries that occurred in 2015. The form must be posted from February 1 to April 1. Employers must save the OSHA Form 300 log, the privacy case list (if one exists), the OSHA Form 300A, Annual Summary, and the OSHA Form 301 Incident Report for five (5) years following the end of the calendar year that these records cover.
Employers are required to update the 300 logs to include newly discovered recordable injuries or illnesses and to show any changes that have occurred in the classification of previously recorded injuries and illnesses. If the description or outcome of a case changes, employers must enter the new information.
Employers must make the OSHA forms available for inspection and copying by certain government regulatory agencies (e.g., Department of Labor). OSHA forms must also be provided to employees, former employees and their representatives in certain situations, including litigation.
What is a “Recordable” Incident?
According to OSHA, the following must be recorded on an employer’s Forms 300 and 300A:
All work-related fatalities
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
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 (e.g., a cut, fracture, sprain, or amputation)
Acute and chronic illnesses (e.g., a skin disease (i.e. contact dermatitis), respiratory disorder (i.e. occupational asthma, pneumoconiosis), or poisoning (i.e. lead poisoning, solvent intoxication)
Event or exposure in the work environment that either caused or contributed to a actute or chronic illness
Event or exposure in the work environment that significantly aggravated a pre-existing injury or illness
All employers must report directly to OSHA:
- All work-related fatalities within 8 hours.
- All work-related inpatient hospitalizations, all amputations and all losses of an eye within 24 hours.
Fatalities occurring within 30 days of the work-related incident must be reported to OSHA. Further, for an in-patient hospitalization, amputation or loss of an eye, these incidents must be reported to OSHA only if they occur within 24 hours of the work-related incident.
OSHA’s website www.osha.gov is an excellent resource. OSHA has created a new “OSHA Fact Sheet” for more information on the reporting requirements.