At the beginning of this year, OSHA updated its recordkeeping requirements for reporting workplace injuries and fatalities. Two major changes were included in the new rule:
The list of industries that are partially exempt from routinely reporting injuries and illnesses to OSHA was updated. Exempt industries have relatively low incident rates, based on the North American Industry Classification System (NAICS) and data from the Bureau of Labor Statistics (BLS). Also of note, the new rule states that any employer with 10 or fewer employees, regardless of industry classification, is not required to keep records.
The list of severe workplace injuries that all covered employers must report to OSHA is now longer. Furthermore, all fatalities must be reported within 8 hours, and inpatient hospitalizations, amputations, and losses of an eye must be reported within 24 hours of the incident.
So how do you know your organization’s classification and recordkeeping requirements? Every industry is assigned a 6-digit code with an accompanying 2-digit sector code, which indicate the requirements for those businesses. You can locate these codes by:
- Searching keywords about your organization on the NAICS webpage
- Viewing the NAICS industry code tables
- Contacting your local OSHA office or state agency
Those of you who fall under the new recordkeeping rule must prepare and maintain your injury and illness records using the OSHA 300 Log forms, which include:
- The Log of Work-Related Injuries and Illnesses (OSHA Form 300)
- The Summary of Work-Related Injuries and Illnesses (OSHA Form 300A)
- The Injury and Illness Incident Report (OSHA Form 301)
Form 300A must be submitted annually, even if no recordable incidents take place in that year, while Forms 300 and 301 need only be completed if a recordable injury occurs at your worksite. Notably, to ease the burden of extra paperwork, OSHA gives organizations the option to use their own forms, so long as they contain the same information. This is often utilized via insurance forms. If you have further questions about your organization’s specific requirements or completing the forms, you can find the FAQ page on OSHA’s recordkeeping webpage, or watch this tutorial.
I want to highlight the importance of recordkeeping because it isn’t just about following Federal guidelines to avoid penalties and fines, it is a critical method for maintaining safety standards and reducing incident rates. As stated by David Michaels, the Assistant Secretary of Labor for Occupational Safety and Health for the DOL:
“OSHA will now receive crucial reports of fatalities and severe work-related injuries and illnesses that will significantly enhance the agency’s ability to target our resources to save lives and prevent further injury and illness. This new data will enable the agency to identify the workplaces where workers are at the greatest risk and target our compliance assistance and enforcement resources accordingly.”
Tracking when, how, and why safety incidents occur will help us identify and eliminate hazards in worksites, increase training where needed, improve conditions for workers, and ultimately reducing the frequency of injuries and fatalities at work. Recordkeeping is not just something we have to do, it is a crucial step in improving employee safety.