Injury and illness reports aren’t generally fascinating reading material. Even so, the Occupational Safety and Health Administration (OSHA) requires most businesses to fill out detailed reports of work-related injuries and illness and to post them conspicuously. From February 1 through April 30, the logs (known as OSHA Form 300 logs) for the prior calendar year must be displayed in an area where employees can view them.
Depending on the size of your company and the industry you’re in, you may qualify for an exemption. The details are outlined below.
Company Size and Industry
If you had more than 10 employees at any time throughout the year, even if your head count was 10 or fewer for 11-1/2 months, you’re subject to OSHA’s recordkeeping and reporting requirements.
Traditionally, companies in the retail, insurance, finance and real estate sectors have been considered exempt. Since 2015, however, OSHA has used a more elaborate industry classification system to determine “low-hazard” exemption status based on the North American Industry Classification System (NAICS). To find your business’s industry code, visit the NAICS site.
In addition to industries that have long been required to report to OSHA, there’s a list of “partially exempt” industry sectors. And there’s a list of sectors added since 2015, all of which must maintain injury and illness logs. If you’re in doubt about whether your industry is covered by OSHA, contact your area OSHA office to be sure. Also, even if you’re off the hook with federal reporting, check with your state to determine what, if any, state reporting and posting standards you must adhere to.
If you’re new to tracking OSHA reports, here’s a quick reminder of what you need to know. The basic recordkeeping and reporting requirements for companies that fall under the requirement involve these three forms:
- Log of Work-Related Injuries and Illnesses OSHA Form 300 (and others listed below), which you can find on OSHA’s website.
- Summary of Work-Related Injuries and Illnesses (OSHA Form 300A), and
- Injury and Illness Incident Report (OSHA Form 301).
With a little luck, you won’t have any work-related injuries or illnesses to include on those forms, but you’ll still need to keep and post the log even if it’s empty. On the positive side, “no news” is good news.
OSHA Form 300 logs can be highly detailed. In addition to a basic description of an injury or illness, you must also provide the number of days away from work, or working with modified duties. “Modified duties” is considered a work restriction, even if the employee’s job is only changed in a minor way.
What should you do with Form 300 logs once they’re complete? Don’t send them to OSHA, but don’t dispose of them. You could later undergo an OSHA inspection and must be able to show you’ve properly maintained logs or face penalties.
If you’ve never had a serious injury or illness at your business, you might be unaware that such cases need to be promptly reported directly to OSHA, either by telephone or using an online form on OSHA’s website.
Here are the specific deadlines you need to know:
- Reportable events must be logged within a week.
- Events that involve inpatient hospitalization, amputation or eye loss (both of which presumably would also involve an inpatient hospitalization), within 24 hours.
- Fatalities must be reported within eight hours.
Common Reporting Errors
Until you become familiar with keeping OSHA logs, it can be easy to miss details. Here’s a list of common reporting errors to avoid in the event your records are inspected:
- Failing to have a company executive certify the accuracy of data reported on forms.
- Failing to report medical treatment (other than basic first aid, which is exempted).
- Not using or including an employee’s description of the illness or injury.
- Not reporting incidents that involve temporary or contract workers.
- Misclassifying an illness as an injury. Incidents cumulative in nature (for example, noise-induced hearing loss) are generally considered “illnesses.” In contrast, an injury involves a single exposure or event.
- Not reporting an incident because the employee didn’t report it to you until several days afterwards.
- Using work days instead of calendar days to report the number of days away from work or days worked under restrictions necessitated by the injury or illness.
Given the detailed reporting that OSHA requires, you may wonder if all that work benefits your company in any way, apart from the avoidance of penalties. Consider this: The practice of reviewing your own records of reported injuries or illnesses can provide insight on patterns or conditions that you need to address to improve the safety of your workplace. That’s always a win.