New requirements for OSHA Form 300
For 20 years, employers under Occupational Safety and Health Administration (OSHA) jurisdiction, with more than 10 employees have been required to report and maintain records of all work-related fatalities and all work-related hospitalizations, involving three or more employees.
During that time period, OSHA collected the data from approximately 80,000 employers per year in order to calculate specific injury/illness rates for high-hazard industries, including construction.
On January 1, 2015, OSHA expanded what employers must report and who must report. Under the new rule, ALL employers (regardless of how many employees they have) are required to notify OSHA when an employee is killed on the job or suffers a work-related hospitalization, amputation, or loss of an eye.
A fatality must be reported within eight hours and an in-patient hospitalization, amputation or eye loss must be reported within 24 hours. Only fatalities occurring within 30 day of a work-related incident must be reported to OSHA.
Reporting can be done by calling the OSHA hotline (800) 321-OSHA, calling the nearest OSHA area office or using the new OSHA online form at OSHA.gov.
In addition to reporting serious injuries and illnesses, employers with 10 or more employees must record and maintain information related to these incidents using OSHA Forms 300, 300A and 301.
OSHA Form 300 – Log of Work-Related Injuries and Illnesses
In addition to listing the four serious incidents that must also be reported to OSHA directly, OSHA Form 300 should be used to record all work-related injuries and illnesses that resulted in:
- Days away from work, restricted work, transfer to another job, loss of consciousness or medical treatment beyond first aid
- Diagnosis by a physician or other licensed health care professional
- Illnesses, such as skin diseases, respiratory disorders or poisoning
- Cuts, sprains and fractures
- Pre-existing conditions that were significantly aggravated by exposure in the work place environment
OSHA Form 300A – Summary of Work-Related injuries and Illnesses
OSHA Form 300A must be posted in the workplace from February 1 through April 30 and lists all work-related injuries and illnesses that occurred during the previous year. It summarizes the types of incidents recorded on OSHA Form 300.
It lists the number of cases, including total deaths, days away from work, job transfers, work restrictions and other recordable cases. It also summarizes the total number of days away from work and total number of days of job transfers or restrictions. And it recaps the injury and illness types, including the total number of injuries, skin disorders, respiratory conditions, poisonings, incidents of hearing loss and all other injuries.
OSHA Form 301 – Injury and Illness Report
Within seven calendar days of an employer receiving information that a recordable work-related injury or illness has occurred, OSHA Form 301 must be completed. Then OSHA requires that the form be kept for five years after the year in which the incident occurred. Form 301 details all the specific information of a work-related incident, including:
- Employee information
- Name of physician or health care provider
- Location (other than workplace) where treatment was provided
- Information about emergency care or hospitalization
- Date and timing of the incident
- Other information describing the incident and the conditions contributing to it
All three OSHA forms must be completed in a manner that protects the confidentiality of the employees as much as possible. Current and former employees or their representatives have the right to access the injury and illness records, and employers must provide a copy of the relevant records by the end of the next business day.
How OSHA defines first aid
To ensure employers complete the OSHA forms for medical treatment beyond first aid, it’s important to know how OSHA defines first aid. First aid that does not have to be reported includes:
- Use of non-prescription medication at non-prescription strength
- Tetanus immunizations (Note: Hepatitis B and rabies vaccinations are considered medical treatment and must be listed on the forms)
- Cleaning, soaking or flushing wounds on the surface of the skin
- Use of bandages, gauze, pads, eye patches, finger guards or Steri-strips
- Use of massage, hot or cold therapies
- Use of any non-rigid support, such as elastic bandages
- Temporary immobilization devices, such as slings, splints or neck collars, used while transporting an accident victim
- Draining fluid from a blister or to relieve toe nail or finger nail pressure
- Removal of foreign bodies − from areas other than the eye − using irrigation, swabs, tweezers or other simple means
- Drinking fluids to relieve heat stress
Employers are only required to submit the summary data (OSHA 300A), if they are directed to do so in writing, typically through OSHA Survey Form 169B. For more information, OSHA offers training courses and posts FAQs (frequently asked questions) and related on-line sources at OSHA.gov.