OSHA 300 Recordkeeping: Common Questions and 2024 Changes to Electronic Submissions

The Occupational Safety and Health Administration (OSHA) requires many organizations with 11 or more employees to follow recordkeeping requirements, including using specified forms to record significant work-related injuries and illnesses. Recordkeeping aims to identify workplace injuries and illness types, frequency, and severity to help eliminate and control occupational hazards. 

Some organizations must also submit specific data from their records to OSHA each year or when requested in writing by the Bureau of Labor Statistics (BLS). This data is used to improve safety regulations supporting workers' safety and health. This article covers some common questions regarding the OSHA 300 recordkeeping requirements, including recording COVID-19 cases and the updated 2024 electronic submission requirements.

What Records Are Required?

Employers required to follow the OSHA 300 Recordkeeping rule must utilize the OSHA 301 Injury and Illness Incident Report Form or an equivalent form to investigate each incident in the workplace that results in an injury or illness. This investigation form uncovers the incident's details and helps determine case recordability. Many employers already have an incident investigation form, but to be considered an equivalent form and allowed for use, the employer's form must contain the information found on OSHA's 301 Form at a minimum. 

After an investigation form has been completed, if found recordable, the case must be added to the workplace's OSHA 300 Log within seven (7) days of the incident occurring or of the employer learning of the case. The Log is a running total of all recordable cases at the establishment for the calendar year. Details such as the nature of the injury or illness and the number of days associated with time loss or work restriction for each case are identified on the Log. If an employer learns additional details after adding a case to the Log, they must update the case to reflect the changes. 

At the end of the calendar year, employers must tally up the types of cases from the Log on the OSHA 300A Summary Form. The Summary Form doesn't include the specifics of each case, only the total number of each type of case. Even if there are no recordable injuries or illnesses, covered employers must fill out this form. After filled out, a company executive must sign and certify that the information in the Summary is complete and accurate.

Employers must post the previous year's 300A Summary Form in the workplace in a conspicuous location, such as an employee bulletin board, from February 1 through April 30 each year. This means that in 2024, the 2023 Summary must be posted. For workplaces with remote employees, the Summary must be posted wherever the employer virtually displays other required posters, such as an intranet. 

It's important to note that each employer establishment must keep its own records, which must be maintained for five years in addition to the current year's records. This means that in 2024, affected employers must have accurate, updated records for 2019 through 2024 at each establishment.

Which Employers Are Exempt From Recordkeeping Requirements?

Employers with ten (10) or fewer employees (at all times) during the last calendar year are exempt from keeping OSHA records unless OSHA, the BLS, or their state safety agency informs the employer in writing that they must keep these records. Additionally, some lower-risk industries, such as schools and many stores, are also exempt from the recordkeeping rules. 

However, all employers, regardless of size or industry, must report any work-related incident that results in a fatality, in-patient hospitalization of one or more workers, an amputation, a loss of an eye, and in some cases, a catastrophic event to their local OSHA office or state-run agency. Reporting requirements and reporting windows vary by state, so employers are encouraged to review their state's requirements. 

What if Employers Have More Than One Establishment?

Employers must maintain OSHA 300 records for each establishment expected to operate for at least one year. An establishment is a single physical location where business or operations are conducted. Suppose an employee works in multiple locations or works remotely. In that case, the establishment is considered the office, terminal, or station that supervises the employee or serves as the base for work.

What Makes a Case Recordable on the OSHA 300 Log?

Just because an employee seeks medical treatment does not mean the case is recordable on the establishment's OSHA 300 Log. Work-related injuries and illnesses that meet one or more of the general recording criteria need to be added to the Log. These general recording criteria include:

• Situations that require medical treatment beyond first aid;
• Cases that involve days away or restricted work;
• A loss of consciousness;
• A worker death;
• If the worker sustains a needlestick or sharps injury from an object contaminated with another person's blood or potentially infectious material (OPIM);
• When there is confirmed hearing loss; or
• A healthcare provider diagnoses a significant illness, such as cancer, tuberculosis, or musculoskeletal disorders.

Employers should not track injuries or illnesses that only receive first aid treatment on the Log. First aid is care typically administered immediately after the injury, often at the incident's location. However, it can also include one-time, short-term treatment requiring little technology or training. Examples of first aid include:

• Cleaning minor wounds and applying bandages;
• Removing debris from the eyes by flushing or a cotton swab, or the use of an eye patch;
• Treating sprains and strains with hot or cold therapy, massage, and the use of slings;
• The use of non-prescription, over-the-counter medicines such as ibuprofen; and
• Immunizations such as tetanus shots.  

Using diagnostic procedures, such as X-rays, doesn't automatically make the case recordable either. However, if a healthcare provider prescribes medications, even over-the-counter medications at prescription strength (e.g., 800 mg of ibuprofen instead of the 400 mg recommended on the container), or provides medical treatment beyond first aid (e.g., stitches, chiropractic manipulation, applying a cast, or surgery), the case becomes recordable. 

Do COVID-19 Cases Need to be Recorded?

In 2020, OSHA updated its recordkeeping requirements to specify that COVID-19 is a recordable illness, and employers are responsible for recording the case if:

• The case is a confirmed case of COVID-19, as defined by the Centers for Disease Control and Prevention (CDC);
• The case is work-related as defined by 29 CFR 1904.5; and
• The case involves one or more of the general recording criteria, such as treatment beyond first aid, days away or restricted work, a loss of consciousness, or death.

A case could also be recordable if the employee suffers a severe reaction to an employer-required COVID-19 vaccine and meets the recording criteria. 

Remember that an employee diagnosed with COVID-19 is not an automatic cause for recording the case on the Log. Employers only need to record work-related cases, such as an event or exposure in the work environment that either caused or contributed to the resulting condition or significantly aggravated a pre-existing condition. The employer's responsibility is to identify the event or situation that led to the employee exposure, such as several employees getting sick with COVID after working in the same area. If a case is work-related, it will likely be recordable on the Log because a required isolation period will typically meet the "days away from work" element of the general recording criteria. 

Do Injuries That Occurred While Working From Home Need to Be Recorded on the Log?

OSHA considers the employee's home office part of their work environment, so injuries that occur while working remotely could be recordable. However, like COVID-19 cases, the incident must be work-related and meet the general recording criteria (i.e., treatment beyond first aid, time loss, etc.). Questions the employer should ask when determining whether a case is recordable or not include:

• Did the incident occur during paid work time?
• Was the incident directly related to the employee's work duties?
• Does the case meet the general recording criteria?

An example of a case that would be recordable is one where the worker develops an occupational disease, such as carpal tunnel, that is directly related to sitting at a computer all day. The worker has surgery to fix the issue, missing time from work. A case that would not be recordable would be an employee spraining their ankle while going for a run during their lunch break. 

Updated Electronic Submission Requirements

In addition to OSHA 300 maintenance and posting requirements, many establishments must also electronically submit some information from their previous year's OSHA 300 records directly to OSHA each year. This information must be submitted using OSHA's online Injury Tracking Application (ITA) by March 2 each year. 

The electronic submission requirements were first introduced in 2016 but have evolved since then, with the latest requirements becoming effective January 1, 2024. All employers are encouraged to review the updated criteria to determine if their establishment is affected. Establishments with:

• 20-249 employees in certain industries must submit 300A Summary Form information.
• 100 or more employees in designated industries must submit some information from the OSHA 300 Log and the 301 Investigation Forms.
• 250 or more employees in all industries, unless exempt from recordkeeping, must submit 300A Summary Form information.

When submitting data, only select information from these forms will be collected. OSHA will not solicit personal identifying information such as employee names or addresses of treatment facilities. However, OSHA will require establishments to include their company name when they submit. OSHA intends to post the collected establishment-specific and case-specific information online in its Freedom of Information Act Library and maintains that publishing this information will lead to safer workplaces.

While total employer headcount is used to help determine if OSHA 300 recordkeeping rules apply to the employer, electronic submission requirements are based on each establishment's headcount. To determine if electronic submission requirements apply to your workplace, you must first identify the establishment's peak employment during the last calendar year. Each individual employed at the establishment at any time during the year counts as one employee. This includes full-time, part-time, seasonal, and temporary workers. 

How Can Employers Use the OSHA 300 Information?

Although recordkeeping requirements can feel like a burden or seem confusing, there are employer benefits to keeping accurate records. Combining the data collected with workers' compensation claims costs and near-miss records allows employers to identify their facility's safety and incident trends. Once employers understand what's hurting their people, impacting production, and creating losses, they can make corrections to make the workplace safer and more efficient. 

Archbright recommends looking for trends involving specific departments, job tasks, and pieces of equipment or even identifying the most common body parts that get injured. Once identified, trends should be shared with department heads and the employer's Safety Committee, who can help develop targeted, data-driven safety improvements. Many employers have limited resources, whether that's hours in a day or just money available for new equipment. So, safety improvements should be reasonable and impactful. Understanding workplace injury data can help determine what needs fixing and where. Safety doesn't happen by accident – it comes from specific actions taken and implemented as a team, and analyzing recordkeeping data is just one way to get there. 

Need More Help?

Members can find several helpful OSHA 300-related tools in the mozzo Resource Library, including OSHA 300 Excel Recordkeeping Forms, OSHA 300 Recordkeeping FAQs, and a recently recorded OSHA 300 Webinar in the mozzo Video Library. Eligible members with questions about their unique workplace cases can contact Archbright's Safety Consultants or HR Advisors via the Archbright member Hotline or mozzo Chat. Employers that want more information about membership can contact info@Archbright.com.