Establishments subject to injury and illness recordkeeping requirements at 29 CFR 1904 are reminded of their obligation to post completed OSHA Form 300A between February 1, 2018, and April 30, 2018.
Form 300A is a summary of work-related injuries and illnesses from the previous year—in this case, 2017. The form must be posted in a conspicuous area where notices to employees are customarily placed. Also, copies of Form 300A must be provided to employees who do not regularly work on-site. An employer may not deny an employee the right to view completed Form 300A.
Information required in Form 300A includes basic data about the establishment (i.e., name, location, industry description, annual average number of employees, and total hours worked by all employees during the previous year). Required injury/illness information includes number of cases (e.g., total number of deaths, number of cases with days away from work), number of days away from work, and injury and illness type (e.g., skin disorders, respiratory conditions, poisonings). Form 300A must be certified by signature of a company executive as “true, accurate, and complete.”
Information inserted into Form 300A must accurately represent information recorded in required OSHA Form 300—Log of Work-Related Injuries and Illnesses. Furthermore, every injury and illness recorded on OSHA Form 301—Injury and Illness Incident Report—must also be recorded on Form 300. Employers must provide copies of Form 300 free of charge to any employee, former employee, or employee representative no later than the end of the business day following the day of the request. If an employee, former employee, or personal representative asks for a copy of an OSHA 301 Incident Report that describes an injury or illness to that employee or former employee, the employer must provide the form by the end of the next business day.
Forms 300, 300A, and 301 and instructions are available at https://www.osha.gov/recordkeeping/RKforms.html. The forms must be kept by the employer for five years following the end of the calendar year that the records cover.
What Is Recordable?
OSHA regulations for recording injuries and illnesses come with the following provisions:
- Employers with more than 10 employees are required to keep injury and illness records unless they are on OSHA’s list of exempted industries (see list at https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html).
- A recordable illness/injury is:
- Any work-related fatality.
- Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
- Any work-related injury or illness requiring medical treatment beyond first aid (see below).
- Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
- There are also special recording criteria for work-related cases involving needlesticks and sharps injuries, medical removal, hearing loss, and tuberculosis.
- OSHA defines first aid as:
- Using a nonprescription medication at nonprescription strength;
- Administering tetanus immunizations and cleaning, flushing, or soaking wounds on the surface of the skin;
- Using wound coverings such as bandages (but not using other wound-closing devices, such as sutures);
- Using hot or cold therapy;
- Using any nonrigid means of support, such as elastic bandages, wraps, nonrigid back belts (but not using rigid stays or other systems designed to immobilize parts of the body);
- Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards);
- Drilling of a fingernail or toenail to relieve pressure or draining fluid from a blister;
- Using eye patches;
- Removing foreign bodies from the eye using only irrigation or a cotton swab;
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means;
- Using finger guards;
- Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); and
- Drinking fluids for relief of heat stress.
Certain employers must electronically submit data from their injury and illness records to OSHA. In 2018, establishments with 250 or more employees and establishments with more than 20 but fewer than 250 employees in designated high-risk industries must submit information from completed 2017 Form 300A by July 1, 2018. Information and instructions are at https://www.osha.gov/injuryreporting/index.html.