On January 1, 2024, a new Recordkeeping Regulation from the Occupational Safety & Health Administration (OSHA) went into effect. Companies that are designated as “high hazard” will be now required to submit detailed data from their OSHA Form 300 Log and OSHA Form 301 Incident Report in addition to their OSHA Form 300A Annual Summary. Recording and reporting workplace injuries and illness can be confusing, so the breakdown provided here will hopefully help answer some questions and assist businesses in complying with the requirements.
To start, let’s clarify who the OSHA regulations apply to. Except for certain low-risk industries, any establishment with more than 10 employees at any time during the calendar year is required to record all work-related injuries and illnesses. But what does that mean, exactly? Per OSHA definition, the following are considered recordable injuries/illnesses:
- 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
Documents needed
Now that we know who needs to keep injury/illness records and what injuries need to be recorded, let’s review the three key documents needed per the regulations. Remember that this is a completely separate process from a worker’s compensation program. An injury or illness that results in an insurance claim may not necessarily be recordable for OSHA, and an injury or illness that’s recordable per the OSHA regulations may not require a business to file a worker’s compensation claim. Be sure to read through the regulations and if you have questions, reach out to a trusted safety consultant or OSHA directly for assistance.
The first required document is a list of all the recordable incidents that occur for your company throughout the year. Companies can utilize OSHA’s Form 300 “Log of Work-Related Injuries and Illnesses” to keep a running list of all recordable incidents, or an equivalent document that will capture the same data. Information required on the log include the employee’s name and job title, injury date and description, and the number of days the employee was either away from work or had a job transfer or restriction.
But who is considered an “employee” per OSHA? Should your temporary or contract workers be included on your log? The easiest way to define a ‘covered employee’ is one that is on your payroll OR anyone your company supervises on a day-to-day basis. Let’s give a few examples:
- Jill is a full-time employee of Company X and breaks her arm when she slips and falls on the stairs. This is a recordable injury for Company X.
- Joe is a part-time employee of Company Y and must switch jobs for several weeks due to a back injury. This is a recordable injury for Company Y.
- Jane is a temporary employee for Company A, reporting directly to a Company A manager/supervisor, and severely cuts her hand on a piece of equipment requiring stitches. This is a recordable injury for Company A because she was under their supervision when the injury occurred.
- Jim is a contractor for Company B that receives his work assignments from and reports back to a manager at Company Z. Jim cracks his tooth while on the job. This is a recordable illness for Company Z because he was under the supervision of their manager, even though he was at Company B when the incident occurred.
Top form(s)
So, you have your log of recordable injuries and illnesses, and you’re only including those for your covered employees. Do you have a report of the injury or illness detailing what happened? is a free resource you can use to collect and document all the required information about the incident. Like the Form 300, you can utilize your own incident report form as long as it includes all the information OSHA’s form includes, such as information about the employee and health care professional involved, what happened that caused the injury or illness, and details on the injury or illness itself.
The last key document you need for recording your work-related injuries & illnesses is . This is exactly what it sounds like – a summary of the previous year’s Form 300 Log. You provide the total number of cases (injuries/illnesses) you had, the total number of days away from work and days of job transfer/restriction associated with those injuries/illnesses, and the individual totals of the different types of injuries and illnesses (skin disorders, hearing loss, etc.). Two other important data points required include: the annual average number of employees your establishment had along with the total number of hours worked by all employees (OSHA provides a worksheet to help you calculate those last two numbers). The most important thing about the 300A form is that businesses are required to post a physical copy of it in a “conspicuous place or places where notices to employees are customarily posted” from February 1 through April 30 every year.
Even though businesses are required to record your injuries and illnesses, it does not necessarily mean they are required to report them.
To report or not to report
Now that you have your three documents, do you have to report your data to OSHA? If so, what exactly do you have to report, and when do you have to report it? This is where the new requirement comes in.
In 2017, OSHA launched their for companies who are required to submit their injury and illness data do so electronically. Businesses can manually enter data into the application, upload a file, or transmit it electronically. The deadline for submitting previous year’s data into the ITA is March 2. All those details can be found on the .
One of the most frequent questions asked is “am I required to submit my data?” Even though businesses are required to record your injuries and illnesses, it does not necessarily mean they are required to report them. There are three categories of companies that must submit their data to OSHA:
- Establishments with 250 or more employees that are not listed in the .
- Establishments with 20-249 employees at any time during the calendar year and are classified in an industry listed in of the regulations.
- Establishments that had 100 or more employees at any time during the calendar year and are classified in an industry listed in the new of the regulations (high-hazard industries).
What’s new?
If you fall into one of those categories, the next important question is what data you must submit. Everyone in those categories is required to submit their Form 300A. The new requirement is for the third category (those listed in Appendix B) – if that represents your business, OSHA is now requiring you to submit your Form 300 Log AND your Form 301 Incident Reports along with your Form 300A.
It’s strongly recommended to look at this Appendix and review the industries included. Many may be surprised to find their business falls under this new requirement. For some, it might be surprising to see department stores, school bus transportation, and performing arts companies considered "high hazard."
It’s also worth noting that most of the data submitted through the ITA will be made available to the public. OSHA will remove personal information about the impacted employee (age, gender, hire date, if the emergency room or hospitalization was involved) but details about why the incident happened, name/address of the establishment, and the summary of all the establishment’s records will be available.
OSHA believes this level of access will allow organizations, employees, potential employees, and the general public to make more informed decisions about workplace safety and health at a particular establishment, while also giving researchers more data to identify patterns and trends that could ultimately lead to the reduction of occupational injuries and illnesses.
Access to this data will also allow insurers and loss prevention professionals, including 色多多视频and our Casualty Risk Consultants, to work closely with our clients to offer more targeted services and solutions based on the expected higher data quality the OSHA requirements should provide, leading to the opportunity of zeroing in on more transparent areas for improvement.
Wait, there’s more
There are two more important items to note. First, these reporting requirements are based on the size and industry code of the establishment, not the entire company. If your company has multiple sites/locations, each one is considered an “establishment” under the regulation. Therefore, each location should be maintaining their own injury/illness records, calculating their location’s peak employment last year, and looking for their location’s NAICS code in the Appendices to determine if they have to submit their data to OSHA. You can submit all the data for the company under one account within the ITA, so be sure to read through the instructions and the FAQs for details.
Finally, remember that any incident resulting in a fatality, amputation, loss of an eye, or hospitalization of one or more employees must be reported to OSHA regardless of the number of employees you have or the industry you are in. Refer to the regulations for the timeline and details you’ll need for these reports.
There are a variety of resources to turn to for help including insurers like AXA XL. Our Casualty risk consultants offer training on OSHA reporting. There are also new tech-driven solutions offering online OSHA training courses. For 色多多视频clients, such solutions can be provided by one of our Preferred Partners, accessible through the at preferential rates.
Christina Roll is a Casualty Risk Consultant with AXA XL. Based in Atlanta, she can be reached at christina.roll@axaxl.com.
