OSHA Injury and Illness Recordkeeping

Accurate and clear reporting of incidents is essential for assessing the current level of workplace safety, finding areas that need improvement, and preventing similar incidents from happening again in the future. 

Many companies are working on finalizing their recordable injury and illness information from calendar year 2023 and submitting this information to relevant organizations. 

While some companies will be required to submit injury and illness information directly to OSHA under the electronic recordkeeping standard, ISN Hiring Clients will also require all contractors and suppliers (regardless of their size or industry) to submit their 300A Summary and 300 Log into ISNetworld by March 1, 2024. 

To further help with completing recordable injury and illness information, here are some best practices and tips. 

How OSHA Defines a Recordable Incident 

• If an injury or illness occurred that required more than first aid, it is considered recordable. To see what OSHA determines as first aid, please click here. As stated on the OSHA website, an injury or illness is recordable if it fits one or more of the following: 
• 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, or punctured eardrums. 
• There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis. 

When to Record COVID-19 Related Events 

Please reference OSHA’s FAQ page to stay updated on COVID-19 information, including when to record COVID-19 on an OSHA 300 Log. Per OSHA, “COVID-19 can be a recordable illness if a worker is infected as a result of performing its work-related duties.” The following need to be true for an employer to be responsible for recording the illness: 

• The case is a confirmed case of COVID-19 (see CDC information     on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19); 
• The case is work-related (as defined by 29 CFR 1904.5); and 
• The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7     (e.g., medical treatment beyond first aid, days away from work). 

Helpful Resources 

• Electronic submissions to OSHA can be completed in its Injury Tracking Application, which also includes some helpful FAQs to guide companies through the process. 
• OSHA provides a fillable form to help with entering incidents. 
• OSHA maintains an FAQ Search Tool, which can be helpful when determining how to handle unique scenarios. 
• If there are any questions on how to handle a specific case for your company, reach out to your Regional OSHA Office representative. 
• Join an ISNetworld Incident Reporting & Classifications Best Practices Webinar on February 14th at 3pm CST or February 15th at 10am CST for the US, or February 14th at 10am CST for Canada. hosted by the ISN Health and Safety Team. Pre-registration is required. 

Note: OSHA has announced a new rule that will expand the submission requirements for injury and illness data for certain employers in high-hazard industries. Starting from Jan. 1, 2024, establishments with 100 or more employees in certain high-hazard industries must electronically submit information from their Form 300-Log of Work-Related Injuries and Illnesses, and Form 301-Injury and Illness Incident Report to OSHA once a year. This is in addition to the submission of Form 300A-Summary of Work-Related Injuries and Illnesses. To learn more about this rule and the list of high-hazard industries, please visit OSHA’s injury reporting website.