January 31, 2023
Commonly asked questions about OSHA’s recordkeeping and reporting requirements
With OSHA recordkeeping deadlines fast approaching, 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 frequently asked questions we receive during OSHA recordkeeping season.
Q: What is the purpose of OSHA’s recordkeeping and reporting requirements?
A: Recordkeeping and reporting requirements:
- Support OSHA’s mission of ensuring safe and healthy work conditions.
- Provide transparency to your employees on the company’s injury and illness record.
- Help the agency 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. You are also required to keep records if OSHA or the Bureau of Labor Statistics has asked you to do so in writing. We recommend that you keep records even if you’re not required to.
Q: What is the OSHA Form 300A?
A: It is a record of work-related injuries and illnesses your business experienced during the previous calendar 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: OSHA Form 300A, Form 300 and Form 301 can be downloaded from OSHA’s website.
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, 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: Can I use the loss runs my workers’ compensation 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 vice versa) 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 day the injury occurred is not counted. Any partial days after the date of injury are recorded as a day of job transfer or restriction for recordkeeping purposes.
Q: What if an injured employee’s lost time started in 2022 and carried over into 2023? Do I have to record the injury on my 2022 log and my 2023 log?
A: No, you only record the injury on one log. All lost time for an injury that occurred in 2022 should be recorded on the 2022 log. If the injured employee is still out on February 1, 2023, estimate the total number of days you expect them to be out and record that number on your 2022 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 workdays.
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 incidence 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 physical 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 or choose to group them on separate logs based on company divisions or geographic regions.
Q: Our agency provides temporary workers. If an employee got injured at a host employer job site, 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 need to record all COVID-19 cases?
A: As of the date of this article, OSHA is still utilizing its 2019 updated interim enforcement guidance for recordkeeping related to the COVID-19 pandemic. An employer must record cases of COVID-19 if the case is confirmed as defined by the Centers for Disease Control and Prevention (CDC), work-related and involves one or more of the general recording criteria. OSHA expects employers to make a good faith effort to determine work-relatedness based on reasonably available information.
Q: What actions do I need to take after I’ve completed the form?
A: You must post the previous year’s OSHA Form 300A in your workplace from February 1 to April 30. For example, you must have the OSHA Form 300A covering calendar year 2022 posted in your workplace from February 1, 2023 through April 30, 2023. OSHA requires employers to post the form in a common area where notices to employees are usually kept.
Q: What should I include on the form if we’ve had zero recordable injuries or illnesses?
A: You must fill out and post the OSHA Form 300A even if your business had no recordable events during the calendar year. In this case, you should include a “0” for each entry in the number of cases, number of days and injury and illness types sections.
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 injury and illness data. Establishments with 250 or more employees, who are currently required to keep records must also electronically report.
As of October 2022, the OSHA Injury Tracking Application has transitioned to using Login.gov. The deadline for submitting information from the 2022 Form 300A is March 2, 2023. Visit OSHA’s Injury Tracking Application page for more information.
More questions?
For more information about recordkeeping requirements, visit OSHA’s website. The site includes a searchable database of FAQs.
You can also watch a recording our OSHA recordkeeping and reporting webinar from January 24.
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. Texas Mutual encourages you to review the governmental regulations and, for specific guidance, contact your local OSHA field office or consult with legal counsel.