OSHA Recordkeeping
March 02, 2021

OSHA Recordkeeping Deadline

OSHA Form 300A Requirements for Employers

OSHA requires certain employers to electronically submit injury and illness data on their onsite OSHA Injury and Illness forms. On February 1, 2021, covered employers must post the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses form) for injuries and illnesses that occurred in 2020. Employers with 10 or more employees must post the completed OSHA Form 300A between February 1 and April 1 even if they had no recordable injuries or illnesses in 2020. The OSHA Form 300A must remain visibly posted until April 30.


Exempt Industries

Employers with fewer than 10 employees and certain low-risk industries are exempt from this requirement. Visit OSHA.gov for a list of partially exempt industries. OSHA injury and illness recording forms are available on the OSHA website: 

 

Online Submissions

Only a small fraction of establishments are required to electronically submit their OHSA Form 300A data electronically to OSHA. March 2, 2021 is the deadline for electronically reporting your OSHA Form 300A for calendar year 2020. To learn more about OSHA’s electronic reporting requirements , visit the OSHA Injury Tracking Application page.

 

About Loss Runs

Employers should know that recording each claim shown on their loss run into the OSHA 300 log may result in over reporting. Policyholders often use their company’s loss runs so to create an OSHA 300 Log of Work Related Injuries and Illnesses, a precursor to completing the 300A Summary of Work-Related Injuries and Illnesses form.  

 

What is Recordable

It is particularly important for companies to understand what is considered “recordable”. For example, an employee who twists an ankle at work may seek treatment at a care facility. If that treatment only consists of diagnostic x-rays, ice, elevation, an elastic wrap, over the counter medication prescribed at nonprescription strength, and loses no time from work and/or requires no modified duty, OSHA considers all of that treatment to be “first aid”. Therefore, the injury is not recordable in the OSHA 300 log. However, the employee was clearly injured and did require treatment resulting in a workers’ compensation claim. That claim would in fact appear on an employer’s loss run but would not be OSHA “recordable”.

Some employers tend to record every accident, recordable or not, in an effort to avoid an OSHA fine. This is a never a good idea and could result in an OSHA inspection. If a company is not sure about recording an incident and decides not to, they should document their decision and file it with their 300 log. However, when in doubt, it is recommended that a company representative consult OSHA’s robust recordkeeping website and use the OSHA Recordkeeping Advisor e-tool on the site, or call their local OSHA office for assistance.


Recordkeeping Resources

  • OSHA Recordkeeping Rule Safety Alert: Download this Beacon Mutual resource for information about the record keeping rule and a brief summary of key provisions. 
  • Beacon offers a OSHA Injury & Illness Recordkeeping Webinar several times a year. The next webinar is scheduled for April 20, 2021. View Webinar Schedule
  • Your insurance carrier cannot make a recordkeeping determination for you. Fortunately, OSHA’s recordkeeping provides the required forms, advisory documents, and training modules, videos and presentations to help employers navigate OSHA’s recordkeeping requirements Visit the OSHA Injury Tracking Application page.

If you have questions, contact Beacon at safety@beaconmutual.com or contact OSHA directly a (401) 528-4669.

 

David Cookson
Written by

David Cookson

LOSS PREVENTION MANAGER

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