OSHA Answers Form 300 Questions
Employers subject to 29 CFR 1904 must record workplace injuries as they occur and post a summary in a public location at the start of each year to inform employees. Employers in non-exempt industries with ten or more full-time-equivalent employees (including temporary workers and contractors) must record each fatality, injury, or illness that:
- Is work-related,
- Is a new case, and
- Results in death; days away from work, on restricted work, or transferred from usual work (DART); medical treatment beyond first aid, loss of consciousness; or a "significant injury or illness" as diagnosed by medical professional.
- Form OSHA 300-A (or authorized equivalent),
- In a place where all employees may view it,
- For at least the time period from February 1 to April 30 of the year following the year summarized.
In late 2014, OSHA amended its injury and illness recordkeeping and reporting rules, expanding the number of facilities subject to the OSHA 300 Log requirement in 29 CFR 1904.
Accurate and timely OSHA recordkeeping and reporting is a crucial responsibility, now more than ever. In 2015, OSHA proposed clarifications to 29 CFR 1904 regarding employers who fail to make and maintain accurate records of recordable injuries and illnesses.
The Agency made it clear that failure to report an injury or illness is an "ongoing" violation—meaning it's subject to fines for each day the employer fails to record the incident. This clarification means the six-month statute of limitations effectively doesn't apply to these violations.
Throughout the past year, OSHA has written several letters of interpretation on workplace injury recording.
OSHA Interpretations on What "Work-Related" Means
11/06/2015: Clarification on the work-related exemption involving personal tasks outside the assigned working hours. Click here to read.
What OSHA says: An injury/illness is not work-related if it is solely the result of the employee performing personal tasks at the establishment outside of their assigned working hours.
10/19/2015: Determining whether an injury or illness is work-related and recordable. Click here to read.
What OSHA says: An injury/illness is work-related if an event or exposure in the workplace caused or contributed to the resulting recordable condition. A case is presumed work-related if the exposure in the work environment is a discernible cause; it need not be the sole or predominant cause. Read more about this interpretation here.
Letters of Interpretation on Work Environment
04/13/2015: Clarification regarding the applicability of the recording criteria for an injury occurring while commuting to and from work. Click here to read.
What OSHA says: A traffic accident occurring during an employee's commute is not considered work-related, even if it involves a company-issued vehicle.
02/12/2015: Clarification of the applicability of the recording criteria for cases occurring while traveling to and from an airport for work-related travel. Click here to read.
What OSHA says: A traffic accident occurring during an employees work-related travel is work-related, including a trip home from the airport on a weekend.
02/10/2015: Clarification regarding the jurisdiction of the applicability of the recording requirements in State territorial waters. Click here to read.
What OSHA says: OSHA's jurisdiction over mobile offshore drilling units (MODUs) is limited due to these workplaces being far off the coast and not always in contact with the seabed. These workplaces may be subject to injury and illness recordkeeping and reporting requirements under OSHA rules at 29 CFR 1904 or those of the US Coast Guard.
Letters of Interpretation on Responsibility to Record
10/19/2015: Determining who is the responsible party to record an injury or illness. Click here to read.
What OSHA says: Large-scale use of temporary employees and/or staffing agencies does not negate OSHA's recordkeeping requirement. Read more about this interpretation here.
06/25/2015: How to maintain logs for employees across multiple locations. Click here to read.
What OSHA says: This letter provides guidance on maintaining injury and illness records for employees who work at multiple locations.
Recordable Injuries by Type of Treatment
07/06/2015: Use of kinesiology tape is not considered medical treatment beyond first aid. Click here to read.
What OSHA says: Injuries are recordable if they require medical treatment beyond first aid. OSHA does not consider kinesiology tape to be medical treatment beyond first aid, countermanding previous guidance. Read more about this interpretation here.
02/12/2015: Clarification regarding the applicability of the recording criteria involving restricted work. Click here to read.
What OSHA says: Injuries are recordable if they cause the employer to restrict the employee from performing any part of the usual work tasks, including removing the employee from a hazardous area and regardless of whether or not any applicable OSHA standard requires such medical removal.
If you've ever wondered whether to record an injury or illness, then the interpretations from OSHA are a great place to find answers. While every workplace is unique, chances are that at some point another safety manager has dealt with exactly what you're facing and may have asked OSHA about it. Also, while these interpretations are not officially codified rules or requirements, they provide useful insight into how OSHA inspectors view the regulations and may enforce them at your facility.
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