The start of the New Year is always a good time to begin collecting information for your OSHA Form 300A if you haven’t already. OSHA Form 300A, Summary of Work-Related Injuries and Illnesses, is used to summarize the recordable injuries and illnesses for the previous year. It includes the number of days work was lost or restricted, and the types of injuries and illnesses that occurred. Information about the company, including the average number of employees, and total hours worked by all employees, must also be recorded.
Form 300A must be posted from February 1 through April 30 each year. If no recordable incidents or illnesses occurred during the previous year, the form must still be completed and posted reflecting zero recordable cases. The information in Form 300A is based on information recorded on OSHA Form 300, Log of Work-Related Injuries and Illnesses. However, certain employers are exempt from these recording requirements.
Employers with 10 or fewer employees are not required to prepare Form 300 or Form 300A. In addition, only industries within certain North American Industrial Classification (NAICS) codes are required to comply with these record keeping requirements. A list of exempt NAICS codes has been published by the Department of Labor. This list includes NAICS code 5417 (Scientific Research and Development Services such as establishments engaged in conducting biotechnology).
Even if your company doesn’t fall under mandatory recording requirements, we encourage as best practice that companies use the forms to record injuries and illnesses. In addition, in some cases, companies in exempt industries may specifically be asked to record injuries and illnesses by OSHA, the Bureau of Labor Statistics, or a state agency. Also keep in mind that all employers, including those exempted by reason of company size or industry classification, must report to OSHA any workplace incident that results in a fatality, in-patient hospitalization, amputation, or loss of an eye.
It’s not always straight forward to determine if an injury or illness is work-related. The OSHA booklet Forms for Recording Work-Related Injuries and Illnesses is very helpful with filling out the forms correctly and helping to determine the work-relatedness of an injury or illness.
An injury or illness is considered work-related if an event or exposure in the work environment caused or contributed to the condition, or significantly aggravated a pre-existing condition. The work environment includes the establishment and other locations where an employee works, or is present, as a condition of their employment. Injuries and illnesses resulting from events or exposures occurring in the workplace are also considered work-related unless an exemption described in 29 CRF 1904.5(b)(2) applies.
Which work-related injuries have to be recorded? As detailed in 29 CFR 1904.7, recordable cases include deaths, loss of consciousness, days away from work, restricted work activity or job transfer, and medical treatment beyond first aid. Work-related injuries and illnesses that are considered significant, and diagnosed by a physician or other licensed medical professional, must also be recorded. These include cases involving work-related cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum.
The following additional conditions also meet the criteria of being recordable when they are work-related: any needlestick injury or cut from a sharp object that is contaminated with human blood or other potentially infectious material; any event requiring an employee to be medically removed under the requirements of an OSHA health standard; a tuberculosis infection; and measurable hearing loss in one or both ears.
Remember, that per current OSHA requirements, COVID-19 can be a recordable illness if a worker is infected as a result of performing their work-related duties. However, employers are only responsible for recording cases of COVID-19 if all of the following are true: the case is a confirmed case of COVID-19 per CDC Guidelines, the case is work-related as defined in 29 CFR 1904.5, and the case involves one or more of the general recording criteria described in 29 CFR 1904.7 (e.g., medical treatment beyond first aid, days away from work).
In addition to the posting requirements for OSHA 300A forms, employers with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries must electronically submit their Form 300A summary data to OSHA. If you are required to submit injury and illness data, please note that new procedures using login.gov became effective in October, 2022.
For additional information about OSHA injury and illness recording and reporting requirements, or for help with preparing your company’s OSHA Form 300A Summary of Work-Related Injuries and Illnesses, please email us at firstname.lastname@example.org.
Happy New Year from all of us at Safety Partners!