Recording Occupational Injuries & Illnesses

September 10, 2002 - 10:09

Find out the proper way to report work-related injuries

One of your most productive employees hobbles up to you
with a sore back. "It's been hurting ever since I moved that puncher to
the other side of the greenhouse," he says. "I think I need to go to
the doctor." What do you do? How do you report it? Who do you tell? How do
you protect yourself? Some of the forms you'll need to fill out have new names
and new numbers, and as with most governmental procedures, there are always new
exemptions, new rules, new deadlines and new guidelines. Read on to keep
yourself apprised of the Occupational Safety & Health Administration (OSHA)
changes so you'll be ready if that employee does come to you with an illness or


Names of new forms.
The new forms are called OSHA Form 300, Log of Work-Related Injuries and
Illness and Form 301, Injury and Illness Incident Report. The OSHA 300 log
replaces the OSHA 200 log, and Form 301 replaces Form 101. Á

Appropriate forms and when to use them. Employers must
now use the 300-numbered forms. The employer may continue to substitute
equivalent forms, such as insurance reports, for the supplemental information
OSHA 301, Incident Report form. Records may be kept in paper format or on a
computer, as long as the computer form is equivalent to the OSHA 300 log.

Special circumstances

Small employer exemption. A partial exemption for small employers remains the same. Those
employers with 10 or fewer employees at all times during the last calendar year
do not need to keep OSHA injury and illness records, unless required to
participate in the annual survey. If at any time during the last calendar year
your company had 10 or more employees, you must keep a log of injuries and
illnesses. The number of employees counted is for your entire company, not just
a single location.

SIC code exemption.
A partial exemption for employers in some establishments in certain industries
remains. Those employers whose primary SIC code is among the exempted do not
need to keep injury and illness records, unless contacted by OSHA to
participate in the survey. Appendix A to Subpart B (following 1904.3) contains
a list of those SIC codes that are exempt. The exempt businesses are, for the
most part, those businesses that do have and are expected to have very low
injury and illness rates, such as retail stores, offices, restaurants and the
like. There seems to be no consideration of ergonomic injuries and illnesses at
this point. Some of the exempted SIC codes might be expected to have high
ergonomic injury rates. If you have access to the net, you can go to to determine your SIC code number.


New rule contents.
The new rules, as they will be printed in the Code of Federal Regulations
(CFR), are much more detailed in explaining how to determine which injuries and
illnesses must be recorded on the OSHA 300 log and how to keep the records
accurate. Basic rules for recording injuries and illnesses have changed very
little, but in the past much of this information was contained in OSHA
assistance guides and interpretation letters. When you get your new materials
or if you have already received them, read over them and call if you have any

Recording deadlines.
The new rules have changed how the time frame is expressed, but they have not
changed the actual amount of time allowed for getting injuries and illnesses
recorded to any great degree. The new rules require all injuries and illnesses
to be entered on the form within seven calendar days of the employer receiving
information that a recordable injury or illness has occurred. The old rules
required entry within six working days. The 2-day weekend cushion has been

Summary posting requirements. style='font-weight:normal'> The annual summary posting period is increasing
starting with the posting of the year 2002 summary portion in 2003. The summary
portions of your OSHA 300 logs for 2002 must be posted from February 1 through
April 30, 2003. The new forms have separate pages for the log and summary
portions and a worksheet to help you fill out the summary portion.

Retention of forms. The
new forms must be kept five years following the end of the calendar year that
these records cover, the same as with the old forms. You must continue to keep
the old forms for five years, discarding the 6-year-old form as you archive the
most recent form.

Updating old forms in storage. style='font-weight:normal'> You will also be required to update 300 logs in
storage as is currently required for the OSHA 200 log. Your archived forms must
be updated if employees die or become Á more severely disabled from
work-related injuries or illnesses already recorded. Updating will not be
required for the annual summary or Form 301s (or equivalents). When the new
forms become the required form of use, updating old OSHA 200 logs or 101 forms
in storage will not be required.

Reporting fatalities and multiple hospitalizations. style='font-weight:normal'>The requirement for reporting fatalities and
multiple hospitalizations remains the same - report orally to OSHA within eight
hours of learning about the occurrence. Report in person or call your nearest
OSHA office or call the central reporting number for the Washington, D.C.
office - (800) 321-6742.

Annual survey.
The annual Bureau of Labor Statistics survey will continue to be conducted. Any
employer, regardless of whether they normally have to keep these injury and
illness records, must participate in the annual survey of work-related injuries
and illnesses if notified by OSHA.

About The Author

Dorothy Waters is an attorney and vice president of
Regulatory Consultants Inc. This article was reprinted with permission from The
Safety Sentinel, a publication of Regulatory Consultants Inc.

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