OSHA 300 Series Recordkeeping

Requirements for reporting work-related injuries and illnesses

When it comes to OSHA compliance, it doesn’t get much more basic than complying with the recordkeeping requirements established in 29 CFR 1904. So why is it that OSHA continues to find violations of its recordkeeping rule? Is it because employers simply do not understand that the recordkeeping standard covers them? Or could it be just a basic lack of understanding of the standard and its requirements? Maybe there is a breakdown in the recording because the employer does not have a written procedure in place to ensure work-related injuries and illnesses get promptly and properly reported with timely communication to the individual responsible for maintaining the OSHA injury/illness records.

The reasons for noncompliance are many, but the following are some of the most common causes that can result in failure to comply with the standard:

  1. Failure to maintain the required records, not recording the required injuries and illnesses on the OSHA 300 illness and injury log.
  2. Not recording medical injuries and illnesses as restricted duty days or days away from work.
  3. Not recording the injuries or illnesses in the log within seven days.
  4. Incomplete annual illness and injury summaries certified as being complete and not properly posted on time.

Who Must Maintain OSHA Injury/Illness Records?
OSHA requires companies in most industries, including gases and welding distributors, with 11 or more employees to maintain injury and illness records. This is 11 or more employees in the entire company, not 11 or more at a site. In other words, if you have 11 or more employees, whether at one site or scattered over several locations, your company is required to comply with this regulation.

If you have fewer than 11 employees, you’re not required to keep injury and illness records, but you must report to OSHA, as do all other employers, any workplace incidents that result in a fatality or the hospitalization of three or more employees from a single incident. OSHA must be notified within eight hours from the time you learned about the incident. The notification must be made orally by calling the OSHA area office near the incident site. If the reportable incident is after normal OSHA office hours, or on a weekend or holiday, you must call their toll-free number: (800) 321-6742.

OSHA Forms Required
Three forms are required by the recordkeeping standard:

Log of Work-Related Injuries and Illnesses (OSHA Form 300) – This form must be initiated at the beginning of each calendar year, for each site, by simply inserting the calendar year, establishment name, city and state. You must record information about every work-related case that meets the recording criteria as defined in section 1904 of the standard. The recording criteria for the 300 form is basically deaths, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, and loss of consciousness. More detailed information regarding recording criteria can be found in your GAWDA OSHA Manual, Section 26.

Summary of Work-Related Injuries and Illnesses (OSHA Form 300A) – Each site must complete the Summary of Work-Related Injuries and Illnesses even if no work-related injuries or illnesses occurred during the year. A company executive must certify the summary page for accuracy. A copy must be posted in the workplace from February 1 to April 30 of the year following the year covered by the form.

Injury and Illness Incident Report (OSHA Form 301) – The Injury and Illness Incident Report or an equivalent form must be completed within seven calendar days after you receive information that a recordable work-related injury or illness has occurred. To be considered an equivalent form, any substitute form must contain all the information asked for on this form. There must be an OSHA 301 form or an equivalent form to support each OSHA 300 log entry.

Retention Requirements
You must retain the OSHA 300 log, the 300A annual summary and the 301 incident report form or its equivalent for five years plus the current year.

Gases and Welding Distributors Association
Meet the Author
GAWDA OSHA & EPA Consultant Thomas W. Eynon is senior associate at B&R Compliance Associates LLC, based in Merritt, North Carolina. Members can reach him at (252) 745-7391 and at tom.eynon@brcompliance.com.