What to Know About OSHA Recordkeeping

Important Date:

• OSHA 300 logs are due by March 2, 2025.

Understanding OSHA recordkeeping requirements is essential for ensuring a safe and compliant work environment. Employers are responsible for accurately recording workplace injuries and illnesses on the OSHA 300 Log and ensuring these logs are properly maintained. Organizations must be familiar with the guidelines for when and how to document injuries and illnesses, as this helps mitigate the risk of fines and ensures a safer, healthier workplace.

To help employers better understand these requirements, Chris Pfeiffer, Vice President of Safety at The Horton Group, recently led a webinar detailing OSHA recordkeeping. Below are some key takeaways from the presentation.

Determining Recordability

Certain criteria must be met when deciding whether an injury or illness is recordable under OSHA guidelines. Injuries and illnesses that result in death, days away from work, restricted work, or medical treatment beyond first aid must be recorded. Cases involving loss of consciousness or significant medical intervention are also recordable.

• Recordable injuries are those that result in death, days away from work, restricted work, or medical treatment beyond first aid.
• Cases involving loss of consciousness or significant medical intervention must also be recorded.
• It is important to ensure that any incident meeting these criteria is documented, even if it initially seems minor.

Preexisting Conditions

Suppose a preexisting condition, such as a back injury, worsens due to work activities (e.g., sitting for long periods without proper support). In that case, the injury may need to be recorded as work-related. However, if the employee uses personal equipment, rather than employer-provided tools, the injury might not meet the recordability criteria.

Recording Injuries and Illnesses

Employers must keep an accurate and detailed record of workplace injuries and illnesses. The OSHA 300 Log is the key document for recording such incidents. This log must be completed within seven calendar days of receiving information about a recordable injury or illness. Employers must also complete the OSHA 301 Incident Report form for each recordable injury or illness.

• Injuries must be recorded on the OSHA 300 Log within seven calendar days.
• The OSHA 301 Incident Report form must be completed for each recordable injury or illness.
• Accurate documentation of each incident is essential to ensure compliance and safety.
• Employers with 20 or more employees must submit an annual 300A form.
• Electronic Submission: Employers must submit their OSHA logs electronically, and the system provides guidance on which forms to submit based on the number of employees and the company’s NAICS code. Typically, businesses with 100 or more employees must submit the 300, 301, and 300A forms.

Specific Scenarios and OSHA Compliance

Certain situations require special attention when it comes to OSHA recordkeeping. For example, when a worker is temporarily assigned to another employer, the responsibility for recordkeeping falls to the primary employer, unless the incident occurs while the worker is directly under the control of the temporary employer. Additionally, voluntary company events or remote work scenarios can raise questions regarding whether they fall under OSHA’s recordkeeping requirements.

• When workers are temporarily assigned to another employer, the primary employer is responsible for OSHA recordkeeping unless the incident occurs while the worker is under the temporary employer’s control.
• For voluntary company events, such as parties or social gatherings, injuries that occur may still need to be recorded if they are work-related or occur during work hours.
• Injuries during remote work should be evaluated based on whether the worker’s tasks are directly related to the job and meet OSHA’s definition of a work-related injury.

Staying Compliant and Promoting Safety

Accurate and thorough recordkeeping is essential for OSHA compliance and maintaining a safe workplace. By understanding what constitutes a recordable injury, correctly documenting incidents, and following guidelines for unique scenarios such as temporary workers and voluntary events, employers can reduce risks and ensure workplace safety. Staying informed about recordkeeping requirements helps organizations meet regulatory expectations and foster a safe and healthy environment for all employees. To learn more about how you can keep your employees safe and eliminate risk, check out our safety consulting services.