According to the Occupational Safety and Health Administration (OSHA), maintaining injury and illness records is “easy and beneficial.” For many employers, this requirement is anything but easy, so they outsource this important task to a firm such as Marathon.
From February to April of every year, affected employers are required to display a summary of the injuries and illnesses recorded the previous year at the workplace. This information helps employers, workers and OSHA evaluate the safety of a workplace, understand industry hazards and implement worker protections to reduce and eliminate hazards—preventing future workplace injuries and illnesses.
Have you posted a 2016 summary (OSHA Form 300A) at your workplace, yet? If not, or if you have questions about compliance, we have important information to share with you.
Recordkeeping for OSHA Workplace Injuries and Illnesses
Workplace injuries and illnesses are tracked via three OSHA 300 forms:
- OSHA Form 300 – Log of Work-Related Injuries and Illnesses
- OSHA Form 301 – Injury and Illness Incident Report
- OSHA Form 300A – Summary of Work-Related Injuries and Illnesses
OSHA Form 300A is the summary form that affected employers must display each year. However, both Form 300 and Form 301 must also be properly maintained and used to complete Form 300A.
Maintaining and Posting Records
OSHA requires recording of all serious work-related injuries and illnesses, including death. Minor injuries—those requiring first aid only—do not need to be recorded. In order to comply with maintenance requirements, employers must have staff who can correctly differentiate between serious and minor illnesses, as defined by law. Additionally:
- Employers must report any worker fatality within 8 hours and any amputation, loss of an eye or hospitalization of a worker within 24 hours.
- Starting in 2017, many employers will be required to electronically submit the summary of injuries and illnesses to OSHA.
- All records must be maintained at the work site for at least five years. Also, if requested, copies of the records must be provided to current and former employees or their representatives.
Exemptions from Recording
All but the very smallest employers (10 or fewer employees at all times during the year) or those with a low-hazard industry exemption (see a list here) must maintain and display the required information:
- When counting employees, employers must include full-time, part-time, temporary and seasonal workers.
- This exemption is based on the employment of the entire company rather than per location.
- Employers with more than 10 employees at any time during a calendar year may come under the requirement.
- Even employers in low-hazard industries can be instructed by OSHA to maintain records, based upon their activities and history.
Defining Injury or Illness
OSHA defines an injury or illness as an abnormal condition or disorder. Exposure to an illness doesn’t count, unless it results in signs or symptoms. Injuries and illnesses include cuts, fractures, sprains, skin diseases or respiratory conditions. For OSHA recordkeeping purposes, an injury or illness can also consist of only subjective symptoms such as aches or pain.
Defining Work Related
Work-related illnesses involve more criteria than most employers realize:
- Caused by events or exposures in the work environment.
- Contributed to, exacerbated or significantly aggravated by events or exposures in the work environment.
Defining Severity
The criteria for recording a work-related injury or illness includes:
- Death
- Loss of consciousness
- Days away from work
- Restricted work activity or job transfer
- Medical treatment beyond first aid