It’s Time to Report Accident Data

I had the opportunity to review the recordkeeping forms for many clients last year and was surprised by the many errors I’ve seen. There seems to be some confusion as to what needs to go on the OSHA 300 log, when it has to be recorded, what columns to check, and how to count the days—that’s just about everything!

Most of my clients are in either manufacturing or construction and are required to keep these forms once they employ more than 10 employees at any one time. (Certain low-risk industries are exempted.)

How does OSHA define a recordable injury?

• 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.
• 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.

Minor injuries requiring first aid only do not need to be recorded. The following items are first aid. If it is not on this list it is a medical injury and recordable.

• Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health-care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
• Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment);
• Cleaning, flushing, or soaking wounds on the surface of the skin;
• Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
• Using hot or cold therapy;
• Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
• Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, backboards, etc.). 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); or
• Drinking fluids for relief of heat stress.

The 300 Log must be completed when injuries occur. Companies are required to record injuries or illnesses on the OSHA 300 log within seven days of the employer receiving notification of the incident.

Counting Days

When to begin counting days: You begin counting days away on the day after the injury occurred or the illness began.

Weekends, holidays, or other days the employee would not have worked anyway: You must count the number of calendar days the employee was unable to work as a result of the injury or illness, regardless of whether or not the employee was scheduled to work on those day(s). Weekend days, holidays, vacation days or other days off are included in the total number of days recorded if the employee would not have been able to work on those days because of a work-related injury or illness.

Count limit: You may “cap” the total days away at 180 calendar days. You are not required to keep track of the number of calendar days away from work if the injury or illness resulted in more than 180 calendar days away from work and/or days of job transfer or restriction. In such a case, entering 180.

Restricted work — Restricted work occurs when, as the result of a work-related injury or illness:

(A) You keep the employee from performing one or more of the routine functions of his or her job, or from working the full workday that he or she would otherwise have been scheduled to work; or

(B) A physician or other licensed healthcare professional recommends that the employee not perform one or more of the routine functions of his or her job or not work the full workday that he or she would otherwise have been scheduled to work.

Examples of restriction or transfer include these cases:

• The employee works only for a partial work shift because of a work-related injury or illness
• The doctor recommends a job restriction, but the employee does all of his or her routine job functions anyway
• An injured or ill employee is assigned to a job other than his or her regular job for part of the day

Routine functions —For recordkeeping purposes, an employee’s routine functions are those work activities the employee regularly performs at least once per week.

Counting days of job transfer or restriction

You count days of job transfer or restriction in the same way you count days away from work.

OSHA 300A Form

An OSHA 300A Summary of Work-Related Injuries and Illnesses report must be posted from February 1st to April 30th of each year for the previous calendar year’s OSHA recordable claims.

Posting is required even if no injuries or illnesses occurred during the previous calendar year. Enter zeros on the total lines and be sure the form is signed and dated before posting.

The 300A must be certified (signed) by a “company executive” and posted in a common area/s where employee notices are typically displayed.

Electronic Recordkeeping

Establishments with 20 to 249 employees in certain industries (required for construction and manufacturing)  will continue to be required to electronically submit information from their OSHA Form 300A annual summary to OSHA. The deadline for submission each year is March 2nd, and employers covered by the electronic submission requirements must submit their Form 300A data for the previous calendar year.

All establishments with 250 or more employees that are required to keep records under OSHA’s injury and illness regulation will also continue to be required to electronically submit information from their Form 300A to OSHA on an annual basis, the same as above.

NEW! 301 Reporting Requirements

Only establishments with 100 or more employees in designated industries are required to submit case-specific information from the OSHA Form 300 Log and the OSHA Form 301 Incident Report. Establishments that had a peak employment of 100 or more employees during the previous calendar year meet this size criteria.

OSHA may issue a citation for failure to submit data electronically. Remember even if you did not have any recordable incidents, if you are required to report, you must.

Please contact us if you have questions or need assistance at 951.674.1333 or email [email protected]