2020 OSHA recordkeeping and reporting FAQs

OSHA’s recordkeeping season has officially begun. This means it’s time for businesses across the country to post and electronically report their Summary of Work-Related Injuries and Illnesses, more commonly known as the OSHA Form 300A. To help you prepare, Texas Mutual’s safety services team has compiled a list of commonly asked questions that we typically receive during OSHA recordkeeping season.

Q: What is the purpose of OSHA’s recordkeeping and reporting requirements?
A: Recordkeeping and reporting requirements help support OSHA’s mission of ensuring safe and healthy work conditions. Recordkeeping provides transparency to your employees on the company’s injury and illness record. Additionally, data collected by the agency is used to track trends and determine methods of inspection and outreach.

Q: Am I required to keep records?
A: Employers with more than 10 employees, who are not listed as an exempt industry, are required to keep records of injuries and illnesses. 

Q: What is the OSHA Form 300A?
A: It is a record of work-related injuries and illnesses your business experienced during the previous year. It provides a summary of the Form 300, which lists more detailed information about each incident. The summary presents a snapshot of recordable injuries and illnesses. It does not include identifying information, such as employee names.

Q: Where can I get the forms?
A: You can download the OSHA Form 300A on OSHA’s website, along with the other two recordkeeping forms: OSHA Form 300 and OSHA Form 301.

Q: What types of injuries and illnesses do I need to include on our log?
A: In general, you should record work-related injuries and illnesses that resulted in death, loss of consciousness, days away from work, restricted work duties or job transfer or medical treatment beyond first aid. To view additional criteria and more detailed information, download OSHA’s instructions for completing the forms.

Q: When am I required to post the form, and where do I have to post it?
A: You are required to post the OSHA Form 300A between February 1 and April 30 of every year, even if you experienced no recordable injuries or illnesses during the previous year. OSHA requires employers to post the form in a common area where notices to employees are usually kept.

Q: Can I use the loss runs my workers’ comp carrier provides to complete the summary?
A: No. Your loss runs may not match the information you are required to include on your OSHA 300 log. This is because not all recordable injuries are filed as workers’ comp claims and the days away from work are tracked differently for the claims process.

Q: If an employee misses a partial day of work, how do I record that on the log?
A: The initial day of the injury is not counted. Any partial days are recorded as a day of job transfer or restriction for recordkeeping purposes.

Q: What if an injured employee’s lost time started in 2019 and carried over into 2020? Do I have to record the injury on my 2019 log and my 2020 log?
A: No, you only record the injury on one log. All lost time for an injury that occurred in 2019 should be recorded on the 2019 log. If the injured employee is still out on Feb. 1, 2020, estimate the total number of days you expect them to be out, and record that number on your 2019 log. You can amend the record later if needed, once the employee returns to work. For recordkeeping purposes, OSHA places a 180-day maximum on lost work days.

Q: How can I calculate my incidence rate?
A: You can calculate your incidence rate by using this formula:

Total number of injuries and illnesses X 200,000 / Number of hours worked by all employees = Total recordable case rate

The Bureau of Labor Statistics website offers more information about calculating incident rates, as well as an incidence rate calculator tool.

Q: If we have multiple office locations, does each location fill out the OSHA 300 log and post the summary?
A: You must keep a separate OSHA 300 log for each location that is expected to be in operation for one year or longer.

Q: We have temporary locations. Do they fill out the OSHA 300 log, or is it just the main location that fills it out?
A: You must keep a separate OSHA 300 log for each establishment that is expected to be in operation for one year or longer. If you have locations that will be in operation for less than one year, you do not have to keep separate OSHA 300 logs. You may keep one log that covers all of your short-term establishments. You may also include the short-term establishments’ recordable injuries and illnesses on an OSHA 300 log that covers short-term establishments for individual company divisions or geographic regions.

Q: Our agency provides temporary workers. If an employee got injured at a host employer jobsite, who is responsible for recording the injuries?
A: OSHA requires the employer who provides day-to-day supervision to record temporary worker injuries. That typically means the host employer is required to record the injury.

Q: Do we also need to submit this information electronically to OSHA?
A: The electronic reporting rule is based on the size of the establishment (a single physical location) rather than the size of the entire company. Establishments with 20 to 249 employees, who are listed on the required industry list, must electronically report. Establishments with 250 or more employees, who are currently required to keep records must also electronically report. The deadline for submitting information from the 2019 Form 300A is March 2, 2020. Visit OSHA’s electronic submission page for more information. 

More questions?
For more information about recordkeeping requirements, visit OSHA’s website. The site includes a searchable database of FAQs.

Note: Texas Mutual Insurance Company offers this information as general guidance. The company does not represent OSHA, nor do its employees speak on OSHA’s behalf. This guidance does not constitute legal advice. The company encourages you to review the governmental regulations and, for specific guidance, contact your local OSHA field office or consult with legal counsel.

Courtesy of Texas Mutual Blog

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