OSHA Recordkeeping rules are always on the minds of HR professionals late in the year as they complete the OSHA 300 log, the OSHA 300 A summary form and prepare to enter data online into the OSHA Injury Tracking Application. Below is a bit a guidance on who needs to fill out those forms and how.
OSHA Recordkeeping: What You Need to Know for Year-End Compliance
OSHA Recordkeeping rules are always on the minds of HR professionals late in the year as they complete the OSHA 300 log, the OSHA 300 A summary form and prepare to enter data online into the OSHA Injury Tracking Application. Below is a bit a guidance on who needs to fill out those forms and how.
Who needs to keep an OSHA Log?
Many but not all employers. Exceptions are based on:
• Small employer exemption – 10 or fewer employees at all times during the year
• Low-hazard industry exemption – see list of Partially Exempt Industries (PDF)
What forms must be completed?
OSHA Form 300– Log of Work-Related Injuries and Illnesses
OSHA Form 301– Injury and Illness Incident Report (or an acceptable substitute. In NY, a C-2 qualifies as an acceptable substitute)
OSHA Form 300A – Summary of Work-Related Injuries and Illnesses (filled out once per year and posted from February 1 through April 30)
OSHA Forms can be found here.
What needs to be recorded?
Any non-exempt organization must enter information on any work-related injury or illness that results in the following:
• Death
• Loss of consciousness
• Days away from work
• Restricted work activity or job transfer
• Medical treatment beyond first aid – see definitions here.
The recordkeeping rule also contains special criteria for recording occupational hearing loss, tuberculosis, injuries from needlesticks and sharps potentially contaminated with bloodborne pathogens, and cases involving medical removal required by other OSHA standards. All recordable cases should be recorded on an OSHA log within 7-days of the incident.
What needs to be entered online?
Only a small fraction of establishments are required to electronically submit their Form 300A data to OSHA. Establishments that meet any of the following criteria DO NOT have to send their information to us. Remember, these criteria apply at the establishment level, not to the firm as a whole. An establishment is a single physical location where business is conducted or where services or industrial operations are performed. For activities where employees do not work at a single physical location, the establishment is represented by main or branch offices that either supervise such activities or are the base from which personnel carry out these activities.
• The establishment's peak employment during the previous calendar year was 19 or fewer, regardless of the establishment's industry.
• The establishment's industry is on this list, regardless of the size of the establishment.
• The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment's industry is not on this list.
If you meet the criteria, you can log onto the OSHA Injury Tracking Application to enter your organization’s information.
You can ask Friedlander Group’s Safety Specialist, Ray Sullivan (raymonds@friedlandergroup.com), any OSHA recordkeeping questions or check out the OSHA website.
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