OSHA Recordkeeping: It’s that time of the year again!

OSHA Recordkeeping: It’s that time of the year again!
Brian Rutherford, Printing Industry Regulatory Specialist

The Occupational Safety & Health Administration (OSHA) requires employers to keep track of certain injuries and illnesses that occur to members of their workforce during the course of the year. This is a requirement of both federal OSHA and those states with their own approved OSHA agencies.
 
Each January, your company (with only a couple of exceptions) is required to tabulate the information on the OSHA Form 300, Log of Recordable Injuries and Illnesses, and transfer the information over to an OSHA Form 300A, Summary of Recordable Injuries and Illnesses. The OSHA 300A Summary must be posted prominently for employee review from February 1 through April 30.
 
A relatively new requirement is for this information to be uploaded – by your company – to OSHA’s website, where a data collection effort is continually underway to assist various federal and state agencies in identifying injury and illness trends among various industry sectors – and target employers with “high injury rates.” Unfortunately, it is quite easy for a smaller employer (less than 100 employees) to end up on this list for a targeted inspection with only one injury, such as a muscle sprain, resulting in a few days of “light duty.”
 
OSHA recordkeeping is an important issue for all companies, as these documents will be requested immediately upon arrival by compliance officers. During fiscal year 2021, the lack of, or improper OSHA recordkeeping, was the ninth-most-common OSHA violation in the printing industry by number of occurrences – and fifth-most-expensive by penalty amounts.
 
Here’s a quick overview of what is required:
OSHA Form 300, Log of Recordable Injuries and Illnesses
Record all injuries that meet the definition of recordability – work-related fatalities, lost time and restricted duty cases, or cases that involve a loss of consciousness or medical treatment beyond first aid. The OSHA Form 300 should not be “filled out” at the end of the year – it should be kept current throughout the year. In January of the next year, total each column.
 
OSHA Form 300A, Summary of Recordable Injuries and Illnesses
This form is completed in January for the prior year. Once you have totalled all columns on the OSHA 300 Log, you will transfer that information to the appropriate blocks on the OSHA 300A Summary. In addition, you’ll enter the total hours worked by all employees and average headcount. This document should be signed by the top management official at the location, and posted from February 1 through April 30 in a location where employees may view it.
 
OSHA Form 301, Injury and Illness Incident Report
This form documents should be completed at the time of (or shortly after) the incident and captures information about the incident and nature of the injury or illness. In most states, this form is not necessary, as the “First Report of Injury” from your workers compensation carrier is often considered a “suitable substitute” – provided it contains the same information as the OSHA 301. For each entry on the OSHA Form 300, you should have either the OSHA 301 or the First Report of Injury.
 
All OSHA recordkeeping documentation should be retained for at least five years, and should be made available to employees upon request. You will want to ensure there is no protected medical information included in the documentation you retain for OSHA compliance purposes.
 
Instructions and forms are available on OSHA’s website at: www.osha.gov/recordkeeping
 
You may contact Jennie Thomas at jennie@piag.org or Brian Rutherford at brianr@piamidam.org if you have questions. We are also hosting a webinar on January 25 to help your key contact for OSHA recordkeeping ensure they are aware of the requirements and pitfalls of this important topic! Learn more and register.