OSHA Injury and Illness Record Keeping

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Who falls under this regulation?

Employers with 11 or more employees at any time during the prior calendar year unless industry code is listed on the Partial Exempt List.

When?

Work related injury and illness should be logged on the OSHA 300 within 7 days of knowledge

Deadlines: Feb 1, 2022

You will be required to post only the 2021 Summary 300a form from Feb 1, 2022 through April 30, 2022 in an area visible to employees.

Forms Required:

Employers that are required to maintain Injury and Illness records will need three forms:

  • the Log of Work-Related Injuries and Illnesses (OSHA Form 300),
  • the Summary of Work-Related Injuries and Illnesses (OSHA Form 300A), and
  • the Injury and Illness Incident  Report (OSHA Form 301 or Workers Comp First Report of Injury C2/eFroi).

Instructions:

Watch this 15 min video for a tutorial on completing the Recordkeeping Forms.

Things to Consider:

What type of Injuries or Illnesses are NOT recordable:

  • Employee presented as a member of the general public
  • Symptoms arising in work environment that are solely due to non-work-related event or exposure, (regardless of where signs or symptoms surface). A case is work-related only if a work event or exposure is a discernable cause of the injury or illness or of a significant aggravation to a pre-existing condition.
  • Voluntary participation in a wellness program, medical, fitness or recreational activity
  • Eating, drinking or preparing food or drink for personal consumption
  • Personal tasks outside assigned working hours
  • Personal grooming, self medication for non-work-related condition, or intentionally self-inflicted
  • Common cold or flu
  • Mental illness, unless employee voluntarily provides a medical opinion from a physician or licensed health care professional (PLHCP) having appropriate qualifications and experience that affirms work-relatedness
  • Visits to a licensed physician solely for observation or counseling
  • Diagnostic procedures including x-rays, MRIs, CT scans
  • If the incident involves no lost time and the treatment received does not got beyond the following First Aid List
    • Using nonprescription medication at nonprescription strength
    • Tetanus immunizations
    • Cleaning, flushing, or soaking surface wounds
    • Wound coverings, butterfly bandages, Steri-Strips
    • Hot or cold therapy
    • Non-rigid means of support
    • Temporary immobilization device used to transport accident victims
    • Drilling of fingernail or toenail, draining fluid from blister
    • Eye patches
    • Removing foreign bodies from eye using irrigation or cotton swab
    • Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
    • Finger guards
    • Massages
    • Drinking fluids for relief of heat stress

Special Consideration:

  • Recording workplace exposures to COVID-19

OSHA recordkeeping requirements mandate covered employers record certain work-related injuries and illnesses on their OSHA 300 log (29 CFR Part 1904).

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:

  1. The case is a confirmed case of COVID-19 (see CDC information on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19);
  2. The case is work-related (as defined by 29 CFR 1904.5); and
  3. The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7 (e.g., medical treatment beyond first aid, days away from work).

Employers should follow the OSHA enforcement guidance found in the Updated Interim Enforcement Response Plan for Coronavirus Disease 2019 (COVID-19).

Visit OSHA’s Injury and Illness Recordkeeping and Reporting Requirements page for more information.

  • Travel:
  1. An injury or illness that occurs while an employee is on travel status is work-related if it occurred while the employee was engaged in work activities in the interest of the employer, otherwise it is not recordable.
  2. Detour for personal reasons is not work-related
  • Work from Home:

Injuries and illnesses that occur while an employee is working at home are work-related if they:

  1. Occur while the employee is performing work for pay or compensation in the home, and
  2. Are directly related to the performance of work rather than the general home environment

Day counts (days away or days restricted)                  

    • Do not count day of injury/illness
    • Count the number of calendar days the employee was unable to work (include weekend days, holidays, vacation days, etc.)
    • Cap day count at 180 days away and/or days restricted
    • May stop day count if employee leaves company for a reason unrelated to the injury or illness
    • If a medical opinion exists, employer must follow that opinion
    • Logs are to be completed within 7 days of the injury/illness

Incident Rate Calculation –          Total number of injuries & illnesses multiplied by 200,000

divided by number of hours worked by all employees = total recordable case rate

Online Calculator

For more info please visit OSHA.gov or call your Keevily Team.