To record or not to record? OSHA recordable injuries is an area where I get a lot of phone calls from nervous clients seeking advice on this. There is always a lot of confusion from company owners that wonder when an injury needs to be recorded on their OSHA 300 log. Let’s see if we can simplify this for you so OSHA recordable injuries are a little more straight-forward in the future. This information is also presented on OSHA’s website as a guide for company owners on OSHA injury reporting.
What are considered OSHA recordable injuries or illnesses?
The following work-related injuries must be recorded on the OSHA Form 300:
- Loss of consciousness
- An injury that results in an employee requiring days away from work
- An injury that results in an employee being restricted from work
- An injury that results in an employee being transferred to another job
- An injury that requires any type of medical treatment beyond first aid
- A diagnosis of cancer or chronic disease that is work-related
- Fractured or broken bones or teeth
- Punctured eardrums
In addition, special recording is required for any of the following injuries involving:
- Needles and sharps
- Medical removal
- Hearing loss
What is considered an injury?
OSHA defines an injury or illness as an abnormal condition or disorder. Examples of injuries include cuts, fractures, sprains, skin diseases, or respiratory conditions. Subjective symptoms such as aches and pains are also considered injuries. Exposures are not considered injuries unless it results in signs or symptoms. Injuries must only be recorded if they fall into one of the categories above and require more than first aid.
What is considered work-related?
OSHA defines work-related injuries as any event or exposure in the workplace that causes or contributes to the condition or significantly worsens a pre-existing condition.
How does OSHA define first aid?
First Aid is not considered an OSHA recordable injury, but where does First Aid end and medical treatment begin? Let’s take a look at what OSHA considers First Aid.
- Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
- Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment); Cleaning, flushing or soaking wounds on the surface of the skin
- Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
- Using hot or cold therapy;
- Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
- Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.). Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
- Using eye patches;
- Removing foreign bodies from the eye using only irrigation or a cotton swab;
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
- Using finger guards;
- Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
- Drinking fluids for relief of heat stress.
Who is required to complete the OSHA recordkeeping forms?
OSHA requires most employers with more than 10 employees to keep a record of work-related injuries and illnesses. Certain low risk industries are exempt from the recordkeeping requirement unless they are specifically asked in writing to do so by OSHA. A list of these partially exempt industries can be found here.
Which OSHA forms must be completed?
OSHA Form 300 – Log of Work-Related Injuries and Illnesses
The OSHA Form 300 is the log of all work-related injuries and illnesses that is maintained on an ongoing basis. It includes information on the employee’s name, date of injury, where the event occurred, as well as the classification of the injury.
OSHA Form 301 – Injury and Illness Incident Report
This form must be filled out for every recordable injury or illnesses. This form provides more information on the specifics of the incident and must be filled out within 7 calendar days of the incident.
OSHA Form 300A – Summary of Work-Related Injuries and Illnesses
This is the summary form that will be submitted after the end of the year. It includes a summary of the total number of cases, number of days, injury and illnesses types, etc. The form must be completed even if no injuries or illnesses occurred during the year. A copy of the form must be posted in the workplace where it is noticeable to employees no later than February 1st of the following year and it must be kept in place until April 30th.
When must injuries be recorded?
OSHA requires injuries to be recorded within 7 calendar days of learning of the incident. Fatalities must be reported to OSHA within 8 hours of learning of the incident.
You are not required to submit your forms to OSHA but the records must be maintained at the workplace for at least 5 years, and they must be made available to OSHA upon request. Every year from February – April, you will be required to post a summary of all the recordable injuries from the previous year.
I certainly hoped this helped to answer some of your questions on OSHA record keeping requirements. Please feel free to contact us with any questions, clarifications, or for more information on OSHA compliance.