OSHA 300 Injury Reporting

By Natalie Kvochak

Accidents happen, so injuries are an unfortunate reality in the workplace. The Occupational Safety and Health Administration, more commonly known as OSHA, requires that employers with more than ten employees record serious work-related injuries and illnesses. There are three forms that OSHA requires employers to complete each year as part of injury recordkeeping: Form 300, 300A, and 301. These forms must be completed in accordance with OSHA Laws & Regulations Standard 29 CFR 1904.

As an employer, filling out these forms can be overwhelming if you are not well versed in the rules and regulations. NV5 is here to make this process easier for you. In this article, we will discuss some of the most important rules associated with OSHA 300 injury reporting.

Not every injury that occurs in the workplace will be an OSHA recordable injury. So, the most important rule to consider when completing OSHA 300 forms is what does OSHA define as a recordable injury or illness? Per 29 CFR 1904.7, OSHA defines a recordable injury or illness as follows:

• 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 bone or teeth, punctured eardrums.
• Any work-related, significant injury or illness that is diagnosed by a physician or other licensed health care professional.
• Any work-related cases involving needlesticks and sharps, medical removal, hearing loss, and tuberculosis (please note that cases involving these items have their own special recording criteria).

It is important to note that OSHA has also released regulations related to workplace exposure to COVID-19. Under this new regulation, COVID-19 can be a recordable illness if a worker is infected as a result of performing their work-related duties. However, employees are only responsible for recording cases if all of the following are true:

1. 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).

2. The case is work-related (as defined by 29 CFR 1904.5).

3. 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).

Another important rule to consider is, what does OSHA consider to be a work-related injury? Per 29 CFR 1904.5, an injury would not be considered work-related if the following criteria is met:

• At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee.
• The injury or illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside the work environment.
• The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball.
• The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption (whether bought on the employer’s premises or brought in). If employee injury occurs from food that has been contaminated by workplace conditions or supplied by the employer, it would result in a work-related injury.
• The injury or illness is solely the result of personal grooming, self-medication for a non-work-related condition, or is intentionally self-inflicted.
• The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work.
• The illness is the common cold or flu.

The illness is a mental illness; if the employee thinks the mental illness is work related an opinion from a physician or other licensed health care professional must be obtained.

Some injuries or illnesses will require an employee to be away from work, on restrictive duty, or transferred to another job. If this is the case, OSHA requires you to quantify how many days the employee’s job function will be adjusted. So, the next important rule to consider is how do you determine the number of days an employee is away from work, on restrictive duty, or transferred to another job? Per 29 CFR 1904.7, here are some important considerations:

• You begin counting the number of the days away or on restrictive duty/transfer on the day after the injury occurred or the illness began.
• You will include all calendar days so that includes weekends, holidays, vacation days, days the employee was not scheduled to work, or other days off.
• You should first make an estimate for how many days you think the employee will be away or on restrictive duty/transfer and then update the day count when the actual number of days is known.
• Make sure to record the date an employee stopped working or was put on restrictive duty/job transfer to make tracking these days easier.

Here are just three rules to consider when completing your OSHA 300 injury recordkeeping. There are several other rules not included in this article. If you have any questions or concerns regarding your OSHA 300 injury recordkeeping or would like guidance related to other rules not included in this article, our Environmental, Health, and Safety consultants are here to help! Reach out to us for a consultation.