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Reporting Season! OSHA Forms 300, 300A, 301

January 4th, 2021

Reporting season for OSHA is now open! This month, we’ll be highlighting the ins and outs of what that means for your business on our YouTube Channel and podcast. To kick us off, we have this supplementary piece to our upcoming video on OSHA Forms 300, 300A, and 301. Enjoy! And keep an eye out for when the video drops on Wednesday, January 6.

OSHA requires that records of injury and illnesses are maintained throughout the year and reported and also posted inside your workplace annually. There are three forms that OSHA supplies to accomplish this task. All three of these forms or equivalent documentation must be used and submitted to OSHA in most cases, dependent on the number of employees or industry type. The forms are 300, 300A, and 301.

As we all know in the EHS world, maintaining proper records is essential to maintaining the proper safety programs, compliance, and culture necessary to ensure what you’ve implemented is indeed understood and effective. Maintaining records help you, the employer, to better understand trends and leading indicators that you could use to potentially prevent future incidents.

OSHA’s standard 29 CFR 1904 outlines what is required for an injury or illness to be recordable. Some common questions to ask, Did the employee experience an illness or injury? If so, is this a continuance of a previously recorded injury or illness, if not it’s a new case?

Next question to ask, is the case work-related and does it fit the recording criteria?

The definition of work related is basically a case in which an exposure or event in the workplace caused or contributed to an injury or illness. The work environment includes all locations where employees are working or are present as a condition of employment. Tools and work-related materials are also considered part of the work environment. Now in the standard 1904 it does list 9 different exceptions.  Please review to see if any qualify to help you determine if the case is recordable or not.

OSHA defines a recordable injury or illness as:

• 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.
• Basically, beyond first-aid treatment, in most cases is recordable

So, the 3 forms that we have referred to in the video and that you must use to record workplace incidents and illness are:

Form 300 Fill out as the incident or illness happens to help keep track of your records, the OSHA form 300 Log of Work-Related Injuries and Illnesses, for each work-related injury or illness, this form must include the injured employee’s identification and job title, the incident date, a description of the injury, the location of the part of the worksite in which in the injury occurred, and the severity of each case. The severity of each case falls into one of four categories: Fatalities, Days away from work, Job transfer or restriction and all other recordable cases. Just a quick note the total missed time recorded cannot exceed 180 days. You can update the log as needed when new information needs to be added or changed. You can just make the correction; no need to start a new form.

Form 301 is the Injury and Illness Report. Form 301 is for each individual case, unlike form 300, which is a log of all injury or illness cases. Both forms must be updated as incidents occur. Form 301 must be filled out within 7 days after an injury or illness. You can fill out this form by using the information you reported in the 300 form.

Form 300A is the Summary of Work-Related Injuries and Illnesses. The purpose of this form is to summarize all injury and illness incidents by transferring the totals from form 300. All incidents listed on form 300 must be counted and listed as a total on form 300A, even if the total is zero. The form must contain the signature of a company official verifying all the information on the form has been reviewed and is correct. The company official must be either the owner of the company, an officer of the corporation, the highest-ranking company official at the establishment, or that person's supervisor.

So remember what I mentioned above about reporting and posting? Here is an overview and critical dates you need to know.

• If you have 250 or more employees in an industry covered by the recordkeeping regulation, information from forms 300, 300A, and 301 must be electronically submitted.
• If a business has 20-249 employees and operate in an industry with historically high rates of occupational injuries and illnesses, information from form 300A must be electronically submitted. The complete list of higher-risk industries can be found on OSHA’s website.
• If a business maintains fewer than 20 employees throughout the year, they do not have to routinely submit information electronically to OSHA, unless OSHA makes a written request for data. You must post the form 300A without personal information in your facility for the previous year February 1 through April 31. If you meet the criteria to submit the information to OSHA this must be submitted to OSHA by March 2nd of the current year.

Thank you for your time, I hope this helps take the mystery out of these forms and reporting. If you should have questions or need additional help, please feel free to reach out to me and HRP at any time!

Joseph O'Grady, Project Manager at HRP Associates, Inc.