There are three OSHA recordkeeping forms that you should we aware of as an employer. These include the OSHA 300 Log, the OSHA Form 301 and the OSHA 300A. The OSHA 300 Log is used to record and track work-related injuries and illnesses as well as any associated lost, restricted or transfer days. The OSHA Form 301 is used to describe details associated with work-related injuries and illnesses and to report Workers’ Compensation claims to insurance carriers. It is not unusual for many insurance companies to have an “equivalent” to the 301 Form that they use internally. OSHA allows for the use of an equivalent form, provided that it contains as least the same required information as the OSHA Form 301. The OSHA 300A or annual summary, only includes a summary of work-related injury and illness information including the number of cases, all associated lost and/or restricted days and selected operational information such as the employers address and NAICS or SIC codes. Key requirements of the OSHA 300A are that it must be reviewed by a senior member of the management team, signed to indicate their approval and posted for a specific period of time. Additional information on each of the three forms is contained below. All forms are available at www.OSHA.com.
OSHA 300 Log
The OSHA 300 log is used by each employer’s establishment to record and maintain information about employee work-related injuries and illnesses. An establishment, as defined by OSHA, is a single physical location where business is conducted or where services or industrial operations are performed. This establishment may be the place where employees report for work, operate from, or from which they are paid. A mobile workforce, for those typically in construction, may either keep their own records or be part of the general contractor’s, depending on the reporting relationship. The following is a list of guidelines to use for maintaining an OSHA 300 log:
- Maintain on a calendar year cycle (not fiscal).
- Record cases within seven calendar days of receiving information that a recordable case has occurred.
- Retain for five years following the calendar year to which it relates.
- Maintain during those five years and add/or delete cases as necessary.
OSHA Form 301
If an injury or illness is recordable, a supplementary form must be completed. This form provides more information about the case, including information such as the events leading up to the injury or illness, body parts affected, object(s) or substance(s) involved, etc. This information must be included on this form. This form may be OSHA 301 form, state Workers’ Compensation reports, insurance claim reports, or the employer’s accident report form. The following is a list of guidelines to use for maintaining supplementary records:
- Record cases within seven calendar days of receiving information that a recordable case has occurred.
- Keep the OSHA 301 form current within 45 days at any given time.
- Each establishment must maintain an OSHA 301 or similar form.
- Retain records for five years following the calendar year to which they relate.
OSHA Form 300A
The employer is responsible for preparing an annual summary of injuries and illnesses that occurred during the calendar year. The annual summary, OSHA Form 300A, displays the totals from columns G through M of OSHA 300 Log. The summary also displays the calendar year covered, company’s name and address, company’s annual average number of employees, and total hours worked by all employees covered by the OSHA 300 Log. The 300A is a separate form and does not display any of the personal information shown on the OSHA 300 Log. The 300A also makes it easier to calculate metrics, such as the Total Case Incident Rate (TCIR) and the Days Away & Restricted Time (DART). The annual summary must be:
- Posted by February 1 and remain posted until April 30
- Posted in areas where other notices are normally placed
- Certified (aka signed) by a company executive stating that the information is correct and complete to the best of the employer’s ability
- Retained for five years following the calendar year to which they relate
If no cases are recorded during a reporting period, the summary must still be posted. Zeroes should be entered into all spaces provided on the 300A.
Written by: Jack Fearing, CPEA