When someone is killed or seriously injured in the workplace, the incident must be reported to the Occupational Health and Safety Administration.
Most employers know this. And yet OSHA reporting requirements are sometimes ignored as other, more urgent matters take precedence. In the immediate aftermath of a workplace safety or health incident, rarely is anyone’s first thought, “we need to report this to OSHA.” Reporting, along with recordkeeping, can seem like an unimportant step or unnecessary paperwork—and get delayed or overlooked entirely as a result.
This is a grievous and costly mistake. If you don’t record and report incidents to OSHA on time, you could face significant expenses and penalties. The minimum fine for a single late or missing report is $5,000.
Moreover, if you neglect your OSHA reporting and recordkeeping duties, you put your workforce and bottom line at risk. Reporting to OSHA keeps your organization in compliance and gives you the information and visibility you need to improve workplace safety and minimize incidents.
Here’s what you need to know about OSHA reporting and OSHA recordkeeping: including what needs to be reported, the difference between OSHA reportable and OSHA recordable, exemptions from reporting and recordkeeping, and more:
What Is an OSHA Recordable Incident?
Not every injury or illness needs to be recorded and reported to OSHA. To be considered recordable, an injury or illness must be work-related and require medical attention beyond first aid.
Is it work-related?
Some injuries and illnesses that seem to happen in the workplace are not, in fact, work-related incidents as far as OSHA is concerned. The following are examples of non-work-related injuries and illnesses that do not need to be recorded:
- injuries that occur to the general public
- certain parking lot accidents
- non-work-induced mental illnesses
- colds and cases of flu
- injuries that arise from personal meals or grooming
- injuries that are self-inflicted or from self-medication
- injuries occurring on the premises due to outside factors (such as a natural disaster)
What counts as “first aid?”
OSHA makes distinctions between illnesses and injuries that can be adequately treated with first aid and those incidents that require further medical attention. Sometimes the distinction is obvious: Removing a splinter? You probably don’t need to record it. Amputating a finger? You probably should record that.
Other times, as in assessing the difference between administering a tetanus shot and another immunization, the situation demands knowledge of OSHA’s particular rules around first aid.
- Easily treatable injuries don’t need to be recorded. Examples of sufficient first aid treatments include splinter removal, the use of finger guards, drinking fluids for relief of heat stress, and hot and cold therapy, as well as the process of cleaning, flushing, and soaking wounds.
- You don’t need to record the use of nonprescription medications, such as aspirin and other over-the-counter treatments.
- You technically don’t need to record the use of eye patches—although it’s more than likely that any injury or illness involving the eye will turn out to be a recordable case.
For OSHA’s full list of what counts as “first aid,” click here.
What Should Be Reported to OSHA?
All employers must report workplace-related fatalities and serious injuries to OSHA. In most cases, that means recordable workplace incidents need to be reported, frequently within hours.
Fatalities must be reported to OSHA within 8 hours.
Serious injuries must be reported to OSHA within 24 hours. Examples of serious injuries include…
- Any in-patient hospitalization of one or more employees as a result of a work-related incident. This encompasses all formal admissions to the in-patient service of a hospital or clinic for care or treatment. Note that hospitalization doesn’t necessarily mean that the employee stays overnight; if they’ve been admitted for in-patient treatment, the event must be reported.
- Any employee amputation as a result of a work-related incident. An amputation is defined as the traumatic loss of a limb or other external body part. This includes full and partial amputations—parts that have been severed, cut off, fingertip amputations (with or without bone loss), medical amputations resulting from irreparable damage, and amputations of body parts that have since been reattached. Non-amputations include avulsions (tissue torn away from the body), enucleations (removal of the eyeball), deglovings (skin torn away from the underlying tissue), scalpings, severed ears, and broken or chipped teeth.
- Any employee loss of an eye as a result of a work-related incident.
If a fatality occurs within 30 days of the work-related incident, or if a serious injury occurs within 24 hours of the work-related incident, you must also report the event to OSHA.
OSHA reportable vs. OSHA recordable: What’s the difference?
Some occupational health and safety incidents need to be reported and recorded. Others only need to be recorded. And in some cases (see the section on exemptions below), an incident doesn’t need to be reported or recorded.
Any work-related fatality or serious injury must be reported to OSHA. Period. This includes any injury that involves in-patient hospitalization, amputation, and/or the loss of an eye.
If your business has over ten employees, you must also record these sorts of incidents by filling out OSHA forms such as Form 301, Form 300, and Form 300A. Other kinds of incidents, including injuries that don’t fall into the “serious” category, should be recorded on these forms as well. (Note that some businesses with more than ten employees are exempt from some recordkeeping requirements—continue reading to learn more.)
For a guide on the fundamentals of OSHA recordkeeping, click here.
How Do You Report an OSHA Reportable Incident?
Step 1: Determine if the incident is recordable. Are you required to keep OSHA records? If so, ask the following questions:
- Is the incident work-related?
- Does it require medical attention beyond first aid?
If the answer is “yes” on both counts, you need to record it.
Step 2: Determine if the injury or illness is reportable.
If the incident is recordable, it’s probably reportable. Remember, all employers must report workplace-related fatalities and serious injuries to OSHA.
Make sure to report every incident on time:
- If it’s a fatality, it must be reported to OSHA within 8 hours.
- If it’s a serious injury (i.e. it involves in-patient hospitalization, amputation, and/or the loss of an eye), it must be reported to OSHA within 24 hours.
- If a fatality occurs within 30 days of the work-related incident, or if a serious injury occurs within 24 hours of the work-related incident, you must also report the event to OSHA.
Step 3: Report the incident.
Once you’ve determined that an injury or illness is recordable and reportable, you need to inform OSHA about it.
When reporting an incident, be sure to include the following information:
- the establishment name
- the location of the work-related incident
- the time of the work-related incident
- the type of reportable event (e.g. fatality, in-patient hospitalization, amputation, or loss of an eye)
- the names and number of employees who suffered a fatality, in-patient hospitalization, amputation, or loss of an eye
- your contact person and their phone number
- a brief description of the work-related incident
You have three options for filing a report:
- by telephone, to your OSHA area office
- by telephone, to the 24-hour OSHA hotline (1-800-321-OSHA or 1-800-321-6742)
- electronically, using the reporting form at OSHA.gov
Keep in mind that your organization may have different requirements depending on your state. Be sure to check your local OSHA office’s standards and regulations.
Who Is Exempt from OSHA Reporting?
No employer is exempt from OSHA’s basic reporting requirements. Once again, according to OSHA:
- All employers are required to notify OSHA when an employee is killed on the job or suffers a work-related hospitalization, amputation, or loss of an eye.
- A fatality must be reported within 8 hours.
- An in-patient hospitalization, amputation, or eye loss must be reported within 24 hours.
If you’re under OSHA’s jurisdiction, you must report these incidents, regardless of the size, nature, or location of your organization.
What about recordkeeping?
OSHA recordkeeping, on the other hand, isn’t required for every organization (although it’s always a good idea to document everything regardless).
Small organizations are exempt from many OSHA recordkeeping requirements. If you have ten or fewer employees at all times throughout the year, you don’t have to keep safety records. You don’t need to fill out OSHA 300, 301, and 300A forms if you choose not to.
Companies in low-hazard industries are partially exempt. If you operate in what OSHA deems a “low-hazard industry,” your organization must still comply with reporting claims, but you are not required to maintain OSHA 300 logs (although doing so is a best practice). To determine whether your work environment is considered low-hazard, you’ll need to find out your North American Industry Classification System (NAICS) code, then check to see if your code shows up on OSHA’s listing of partially exempt industries. Keep in mind that we’re talking about partial exemptions. If OSHA or any other agency requests that you keep these forms—if the Bureau of Labor Statistics performs a random sampling, for example, and requires you to maintain forms throughout the year—then you’re still on the hook.
Exempted or not, all employers must report workplace-related fatalities and serious injuries. And if you do keep OSHA logs, be sure to maintain your records for at least 5 years.
Why keep workplace injury records?
Even if you aren’t required to keep records, there are plenty of reasons to do it. Consider the following benefits identified by OSHA:
1. Tracking injuries and accidents can improve prevention. Records may expose trends and themes among issues plaguing a facility. If you can anticipate what’s likely to happen, you can proactively protect your workforce (rather than merely responding to incidents), which is the ultimate goal of any environment, health, and safety program.
2. Using data helps identify problem areas and processes to correct hazardous workplace conditions. The more you know, the better you can identify and minimize existing risks. Go a step further and analyze the data, and you’ll be able to determine gaps and insufficiencies in your safety program. You may learn that employees need more training, or that a certain procedure is prone to error.
3. Better administer company safety and health programs. Again, the best way to determine the efficacy of your program is through documented data. By analyzing your records, you can find out if you’re truly, tangibly improving your safety results.
4. As employee safety awareness improves, workers are more likely to follow safe practices and report hazards. Recordkeeping and workplace safety are a virtuous cycle. The more you know, the more awareness you’ll have around the facility in key areas such as training or personal protective equipment. When employees understand that proper use of PPE demonstrably correlates to improved safety, for example, they have no reason not to protect themselves and keep an eye on their co-workers’ behavior.
What Are OSHA’s Reporting Requirements in 2021?
As discussed above, employers with more than ten employees in most industries are required to keep records of occupational injuries and illnesses at their establishments. These records include…
- OSHA 300: Log of work-related injuries and illnesses
- OSHA 300A: Summary of work-related injuries and illnesses
- OSHA 301: Injury and illness incident report
The OSHA electronic reporting rule
OSHA’s reporting requirements have recently changed and now entail electronic reporting. Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, as well as establishments with 20–249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses, must electronically submit some information on an annual basis to OSHA. Moreover, organizations in regulated industries must submit 300A forms through OSHA’s Injury Tracking Application.
OSHA Reporting – Key Dates:
February 1: Workplace Posting Deadline
According to OSHA, “Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year. Also, if requested, copies of the records must be provided to current and former employees, or their representatives. It must be posted in a location that is clearly visible to all employees and new applicants, and it must be kept posted until April 30. In addition, employees have the right to request a copy of the records at any time.”
March 2: Form 300A Data Electronic Submission Deadline
Submitted through the Injury Tracking Application. You don’t have to wait until the 2nd to submit your data. Collection begins on January 2nd.
Don’t let OSHA recordkeeping requirements take more time and energy than necessary.
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