Will OSHA Accept Injury & Illness Forms Made by Software?

A Connecticut employer recently asked OSHA whether documents generated by software can be submitted in place of OSHA injury and illness recordkeeping Forms 300 and 300A.
 

Would OSHA accept the documents generated by (software) as a substitute for the OSHA Form 300 and Form 300A to meet the requirements of OSHA's recordkeeping regulation at 29 CFR Part 1904?

The official OSHA injury and illness reporting forms are available for free online. 

The Standard Interpretation OSHA responded with makes it clear that yes, software-generated injury and illness forms may be acceptable, with two major caveats:

1. The equivalent form must have the same information, be equally understandable, and must be completed using the same instructions as the form it replaces.
2. The software must be able to produce paper copies in accordance with 29 CFR 1904.35 and 1904.40.

Equivalents for OSHA Forms 300, 300A, and 301

29 CFR 1904.29(a) requires employers who are required to keep OSHA injury and illness records to use Form 300, Form 300A, and Form 301, or equivalent forms. Any form that has the same information, is as readable and understandable, and is completed using the same instructions as the OSHA form it replaces, is an equivalent form.

• Form 300 is a daily log of work-related, recordable injuries and illnesses.  
• Form 300A is an annual summary of recordable cases, based on the 300 log.
• Form 301 is a detailed incident report created following any recordable injury or illness. 

Note: Regardless of whether an employer opts to use OSHA’s forms or equivalent forms, these must be available for inspection and copying by authorized government representatives [19 CFR 1904.40(b)].

OSHA Rules for Digital Injury & Illness Records

Employers are permitted to record required injury and illness information on electronic media that are different from the OSHA forms, provided that the electronic forms are equivalent to the OSHA forms they replace.

A computer system may not be used if it cannot produce paper copies of equivalent forms when access to them is needed by a government representative, an employee or former employee, or an employee representative, as required by section 1904.35 or 1904.40.

29 CFR 1904.40(a)

When an authorized government representative asks for the records you keep under Part 1904, you must provide copies of the records within four (4) business hours.

29 CFR 1904.35(b)(2)(iii)

When an employee, former employee, personal representative, or authorized employee representative asks for copies of your current or stored OSHA 300 Log(s) for an establishment the employee or former employee has worked in, you must give the requester a copy of the relevant OSHA 300 Log(s) by the end of the next business day.

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Tags: injury reporting, osha, reporting and recordkeeping