Background
Under the Occupational Safety and Health Administration (OSHA) recordkeeping regulation, covered employers are required to prepare and maintain records of serious occupational injuries and illnesses, using the OSHA Injury and Illness Incident Report (Form 301), the OSHA Log of Work-Related Injuries and Illnesses (Form 300) and the Summary of Work-Related Injuries and Illnesses (Form 300A). This information is important for employers, workers, and OSHA in evaluating the safety of a workplace, understanding industry hazards, and implementing worker protections to reduce and eliminate hazards.
Form 301 is one of the first forms filled out when a recordable work-related injury or illness has occurred. Form 300 is used to classify work-related injuries and illnesses and to note the extent and severity of each case. Employers must keep a log for each establishment or site. Listing a case does not mean the employer or worker was at fault or that an OSHA standard was violated. Form 300A is a summary that shows the total number of injuries and illness for the year.
Reminder to Post OSHA Form 300A
Covered employers must post Form 300A in a visible location in their workplaces every year from February 1 to April 30. Covered employers are those with more than 10 employees and whose establishments are not classified as a partially exempt industry. Those employers must fill out and post the summary annually, even if no recordable work-related injuries or illnesses occurred during the year.
Reminder to Electronically Submit 300A to OSHA
Not all employers must electronically submit information from Form 300A to OSHA. Only covered employers are required to submit through OSHA’s Injury Tracking Application (ITA) by March 2.
Establishments with 250 or more employees that are not on this list, and establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses fall into this category. This ends up being only a small fraction of employers. Those that are required to electronically submit must now provide their Employer Identification Number (EIN) along with the Form 300A Summary data.
Even if your employer is required to electronically submit this information to OSHA, it does not replace the requirement to post Form 300A at your workplace.
OSHA and State Workers' Compensation
Cases that are recorded in the OSHA system may also be compensable under a state's workers' compensation system, but others may not. The two systems have different purposes and scopes. The OSHA recordkeeping system is intended to collect, compile, and analyze uniform and consistent nationwide data on occupational injuries and illnesses. The workers' compensation system, in contrast, is not designed to generate and collect data but is intended primarily to provide medical coverage and compensation for workers who are killed, injured, or made ill at work, and varies in coverage from one state to another.
As a result of these differences between the two systems, recording a case does not mean that the case is compensable under a state's workers' compensation system, or vice versa. When an injury or illness occurs to an employee, the employer must independently analyze the case in light of both the OSHA recording criteria and the requirements of the state's workers' compensation system to determine whether the case is recordable or compensable, or both.
Current and former employees, or their representatives, have the right to access injury and illness records. Employers must provide the requester with a copy of the relevant record(s) by the end of the next business day.
Questions on OSHA recordkeeping? Contact one of MRA’s HR Advisors at 866-HR-HOTLINE (866-474-6854) or [email protected].
Source: DOL.gov; Lynell Meeth, Director, HR and Content Strategy, MRA - The Management Association
