OSHA Recordkeeping and Annual Posting Requirement | All You Need to Know

All worksite employers with 10 or more employees are subject to certain recordkeeping requirements by the federal Occupational Safety and Health Act (OSHA). These requirements are put in place to help employers, employees, and OSHA officials evaluate the safety of a workplace. With precise recordkeeping and reporting, OSHA hopes to create a safer workplace moving forward and encourage employers to incorporate more effective safety training.

As good as OSHA’s intentions may be, the expectations and requirements of employers can sometimes be complex and confusing. In order to avoid any confusion regarding what employers are expected to complete, we’ve put together an article detailing all recordkeeping and posting essentials.

Why does OSHA Require Posting and Recordkeeping?

As previously mentioned, OSHA requires organized posting, reporting, and recordkeeping of all employers to prioritize a safer working environment. Through OSHA’s regulation, employers and employees have been able to come together to find common ground on what it means to have a safe workplace in their respective industry.

OSHA does have an agenda for their requirements of employers. Specifically, OSHA’s goal is to evaluate the safety of a workplace, understand common industry hazards, implement work protections, reduce and eliminate injury-causing hazards, and prevent future injuries and illnesses.

An OSHA Recordkeeping Breakdown

An employer’s records must be maintained at the worksite for at least five years. Such records are required to be kept on OSHA Forms 300 and 301.

• OSHA Form 300: Used as a log of work-related injuries and illnesses. Form 300 is required to be kept on site in a secure place in case of an audit.
• OSHA Form 301: Used as a log of injury and illnesses incident report. Form 301 is used to report and provide details about any injury or illnesses related incident.

It should be mentioned that employers are also required to provide copies of all injury or illness records to both current and former employees upon their request.

An OSHA Annual Posting Requirement Breakdown

All injury and illness postings are also required to be kept and maintained at a worksite for at least five years. Such postings are required to be kept on OSHA Form 300A.

• OSHA Form 300A: Used as a summary of work-related injuries and illnesses. Form 300A is required to be posted in a visible place each year, from February 1^st to April 30^th.

Many employers choose to also post Form 300 in the same place at the worksite as Form 300A. While this may be convenient and easier for employers and employees to keep track of, there are certain caveats that must be addressed.

Employers are not required to post Form 300 alongside Form 300A. If employers do choose to post Form 300 in the workplace, they should post it in an area only accessible to those granted access under the rule; this includes employees, former employees, and employee representatives. If employers do choose to post Form 300 in a place accessible by members of the public, the employer is required to remove or hide all names of the injured or ill employees on the form.

How does OSHA define a recordable injury or illness?

A recordable injury or illness according to OSHA is defined as any work-related:

• Fatality
• Injury or illness resulting in loss of consciousness, time away from work, restriction of work, or transfer of job
• Injury or illness that requires medical treatment beyond first aid
• Diagnoses of cancer, chronic irreversible diseases, fractured or broken bones or teeth, and injured eardrum

OSHA does not require employers to submit reports or keep records of minor injuries. According to OSHA, minor injuries that require only first aid are defined as injuries or illnesses requiring treatments such as non-prescription medication, administered vaccines, basic bandages, or eye patches.

OSHA Severe Injury Reporting

In addition to standard injury and illness recordkeeping, employers are also required to report all severe injuries occurring in the workplace. All employers are required to report severe injuries within 24 hours of the occurrence. Employers are required to report any worker fatality within 8 hours of the occurrence. Occurrences of severe injuries, as defined by OSHA, include:

• Any amputation or loss of limb
• Loss of an eye
• Any type of hospitalization of a worker

To report an injury, employers can either call the nearest OSHA office or the OSHA 24-hour hotline at 1-800-321-6742. While it is recommended to report a severe injury or fatality over the phone, employers can also report online.

In reporting an injury, employers should be prepared to supply the following information:

• Business name
• Name of employee(s) impacted
• Location of incident
• Time of incident
• Brief description of incident
• Contact person and phone number

A Look Forward at OSHA Recordkeeping for Injuries and Illnesses

One of the more confusing reporting elements that employers have to deal with is how regularly OSHA requirements change. OSHA updates their recordkeeping requirements on a regular basis to reflect the most up-to-date safety standards of the times.

Here are a few of the proposed rules (and changes to rules) that OSHA published in 2022:

• Companies with 20 or more employees, in certain high-hazard industries, must continue to electronically submit Form 300A annually to OSHA.
• Companies with 100 or more employees, in the highest-hazard industries, must submit Forms 300 and 301 annually to OSHA.
• Companies with 250 or more employees, not in high-hazard industries, will no longer be required to electronically submit recordkeeping annually to OSHA.

These proposals were published as a part of OSHA’s regular improvement of safety programs. After an analysis of past safety programs, OSHA determined that annual electronic submissions of Forms 300 and 301 improve workplace safety and health in high-hazard industries.

Looking for more information about OSHA Recordkeeping and Annual Posting Requirements?

The recordkeeping and posting requirements for employers can be difficult to comprehend, even after a thorough explanation. With the right tools, information, and processes, any and all employers can meet OSHA’s requirements without too much trouble.

If you are looking for more information on OSHA’s recordkeeping and annual posting requirements, you’ll be able to find all you are looking for on their website. In addition, you can also find links to specific forms here.