Every year about this time we receive a lot of calls asking about OSHA's Form 300. Although most people know that the form is a Log of Work-Related Injuries and Illnesses, they're unsure exactly what their obligation is and what type of injuries have to be included.
There's a group of three forms that are used to document work-related injuries. OSHA Form 300 is the main Log of Work-Related Injuries and Illnesses, OSHA Form 300A is a Summary of Work-Related Injuries and Illnesses and, unless exempt, it's required to be posted annually from February 1st through April 30th. Finally OSHA Form 301 is the Injury and Illness Report and it's used to record details on how each individual injury or illness occurred.
So what's your obligation? Well that depends on the number of employees you have and your industry's designation. OSHA requires any employer with 10 or more full-time employees during the calendar year to keep a log of injuries that occurred during the year. The other factor that determines your obligation is your Standard Industrial Classification or SIC code. The North American Industry Classification System (NAICS) is the standard used by Federal statistical agencies in classifying business establishments for the purpose of collecting, analyzing, and publishing statistical data. Certain industry designations fall under OSHA's list of partially exempt industries and aren't usually required to complete OSHA Form 300, 300A and 301, unless they're asked in writing to do so by OSHA or a state agency operating under the authority of OSHA . Facilities that have to comply with the requirement must maintain these logs for 5 years.
"Most healthcare and dental facilities are considered to be partially exempt and not required to complete or post Form 300A, unless OSHA or a State Program approved by OSHA requests it."
Click on the chart below to see the full list of industry designations on OSHA's partially-exempt list.
Keep in mind that all employers, including those partially exempted by industry classification or size, are still required to report workplace injuries that result in a fatality, in-patient hospitalization, amputation, or loss of an eye to OSHA.
What's considered a work-place injury or illness? An injury or illness must be documented on OSHA Form 300 and 300A if an “event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness.” This would include musculoskeletal disorders like back injuries, carpal tunnel syndrome and tendinitis. Injuries or illnesses should be documented within 7 days of the incident and recording requirements pertain to any employee on your payroll, regardless if they are full-time or part-time. Fortunately, there are exceptions to what types of injuries or illnesses actually need to be recorded.
Any work-related fatality must be included and any injury or illness that involved:
- A loss of consciousness
- Medical treatment beyond first aid
- Days away from work
- Restricted work or a transfer to another job
- A significant injury or illness diagnosed by a licensed health care professional
Keep in mind, there are some situations that might not be deemed recordable. Here are a few examples for your consideration:
- Work-related stress
- Early signs and symptoms of some musculoskeletal disorders.
- Musculoskeletal disorders that an employer does not accept as work-related.
- Many illnesses, like cancer, that the employer doesn't accept as work-related.
- An assault on an employee by a patient that doesn't result in more treatment than first aid.
- An injury that the employer doesn't deem severe enough to seek medical treatment.
What if I'm required to post work-related injuries and illnesses? If your State requires it, OSHA requests it or you just want to post the form, it's important that you only post the Summary of Work-Related Injuries and Illnesses or Form 300A. This form only displays the total number and type of injuries and illnesses that occurred in your workplace during the previous year. This is very important since OSHA requires employee medical records are kept confidential.
What's always required is an OSHA policy that's up-to-date and based on current regulations. These policies include your Bloodborne Exposure Control Plan, Hazard Communications, Medical Waste and other required safety and health policies. Employees training must be conducted and documented annually too. This documentation is absolutely necessary and would be one of the first things requested during an OSHA inspection. Although they're not necessarily required, Forms 300, 300A and 301 are included with our 2020 OSHA Manuals for Healthcare or Dentistry and they're easy enough to complete and keep on hand in case they are ever requested.
If you have any questions about you record keeping obligations or our OSHA or HIPAA Manuals, don't hesitate to call us toll-free at 1-800-522-9308.