Have you posted your Form 300A? OSHA requires this summary of injuries to be posted from February through April of each calendar year for all injuries and/or illnesses reported in the prior calendar year (2018, in this case). This form must be posted, even if your organization had no reportable injuries or illnesses during the 2018 calendar year.
OSHA recently rescinded the requirement that businesses with 250 or more employees must submit Forms 300 and 301 electronically. The Final Rule can be viewed here and goes into effect on February 25, 2019. This rescission of the electronic filing requirement does not, however, remove the burden of reporting work-related injuries and illness from the employer.
Most businesses with 10 or more employees are required to report “serious” work-related injuries and/or illnesses to OSHA on Forms 300, 300A, and/or 301. Several businesses have been identified by OSHA as “low risk,” and have been exempted from this requirement. Among those exempted businesses are car dealers, numerous retail stores, florists, gas stations, pipeline transportation businesses, legal offices, and numerous other professional service businesses (including civic, medical, scientific, and educational services). Minor injuries requiring only first aid need not be reported. The following explanations and definitions can be very helpful in determining an employers’ recordkeeping and reporting needs.
How does OSHA define “first aid?”
OSHA defines first aid as any treatment limited to non-prescriptions medications such as over-the-counter pain relievers, ointments or creams, the use of standard bandages, gauze pads, or butterfly strips, elastic wraps, temporary slings or splints, and other minor treatments such as removal of a splinter or similar foreign item from the body or the removal of debris/foreign body from the eye with water/eyewash or a cotton swab. Cleaning of minor wounds (surface lacerations) and tetanus shots are considered first aid, whereas Hepatitis B, rabies vaccinations, and open wound cleaning are not. Most first aid is administered immediately after an incident or accident occurs, and may be the only treatment received by the worker. An injury of this type would rarely require ongoing medical treatment. An injury of this type would rarely require ongoing medical treatment. Minor burns or lacerations are often treatable under this definition of “first aid,” and require nothing more than the application of topical ointment, a Band Aid, and perhaps a dose of over-the-counter Tylenol or Ibuprofen.
What is a “serious” injury?
All fatalities, loss of consciousness, lost-time injuries, injuries requiring light duty restrictions, injuries requiring ongoing medical treatment, or broken bones or teeth are reportable. Work-related illnesses such as cancer and other irreversible and/or chronic diseases are also reportable. There are special requirements governing needlesticks, sharps injuries, hearing loss, TB, and other injuries more specific to the medical field. Many fall injuries qualify as “serious” under this definition, as they commonly require follow up medical care such as prescription drugs, chiropractic care, physical therapy, or surgical intervention.
FORMS 300, 300A, and 301
Form 301 – Injury and Illness Incident Report
Form 301 is the initial reporting form and is required to be completed within 7 calendar days of knowledge of an accident or injury. This form is a general incident report and is rather self-explanatory. It collects general information about the injured employee (name, address, physician information) and what the employee was doing, how the injury occurred, and the nature of the injury or illness. For example, a warehouse worker may suffer back strain due to improper lifting or may strain his or her neck reaching overhead to extract inventory. The injury would first be reported on Form 301, and the injured worker would detail what work was being performed at the time the injury occurred.
Form 300 – Log of Work-Related Injuries and Illnesses
Form 300 is a listing of injuries and illnesses for the employer’s place of business. This form collects information on injury severity, lost time, and light duty return-to-work data. The document also serves as a master log of workplace accidents and can be a valuable tool in identifying injury trends. This data is critical in developing revised work procedures and corrective action plans to reduce recurrences.
Form 300A – Summary of Work-Related Injuries and Illnesses
Form 300A is completed annually, at the end of the year, and is required regardless of whether or not any injuries occurred during the year. The form tallies an employer’s average number of employees over the course of the calendar year and the total number of reportable incidents for that same time period. This figure is determined by following the instructions on the back of the form.
29 CFR 1904
Recordkeeping and reporting is governed by 29 CFR 1904, which outlines exemptions, record retention, variance requests, electronic submissions, and reporting protocols. This standard houses critical information such as:
• How to determine if an injury or illness is work-related (29 CFR 1904.5)
• What determines whether or not an injury is a “new case” (29 CFR 1904.6)
• Requirements for needlesticks and sharps injuries (29 CFR 1904.8)
• Criteria for work-related hearing loss (29 CFR 1904.10)
• Reporting requirements for fatalities, loss of eye or limb, and hospitalization (29 CFR 1904.39)
○ [NOTE: Fatalities (which may occur as much as 30 days from the date of the accident) must be reported within 8 hours; amputations, hospitalizations, and loss of eye must be reported within 24 hours]
• Retention requirements (29 CFR 1904.44)
Knowing what to expect, and what is expected of you, will help you respond confidently when an accident occurs. Reports of serious injuries may be made via telephone or online, so it is best to familiarize yourself with 29 CFR 1904 and be prepared to respond accordingly.
Are you responsible for OSHA recordkeeping and reporting for your organization? Are you responsible for workforce safety or risk management? Email us or give us a call at (816) 349-0850 to see how we can help design a safety and risk management plan that meets your unique needs.