The U.S. Department of Labor’s Occupational Safety and Health Administration has announced a proposed rule to change recordkeeping requirements for occupational injuries and illnesses. This recordkeeping requirement is often informally known as “OSHA 300 logs.”
Currently, OSHA requires all employers not in a designated industry with 250 or more employees to submit Form 300A, Summary of Work-Related Injuries and Illnesses. Additionally, employers with 20 or more employees in “certain high-hazard industries” such as construction, manufacturing, medical care, and warehouses are required to electronically submit OSHA Form 300A.
This proposed rule would:
- require companies with 100 or employees in certain high-hazard industries to electronically submit Forms 300 (Log of Work-Related Injuries and Illnesses) and 301 (Injury and Illness Incident Report), in addition to Form 300A.
- no longer require employers not in a designated industry with 250 or more employees to submit OSHA Form 300A electronically.
According to OSHA’s press release, if this rule were enacted, it would allow the agency to use its resources to “identify workplaces where workers are high risk” and also allow for more transparency regarding employee safety in the workplace.
It is always important for employers to exercise due diligence when preparing and submitting OSHA Form 300A, but it will be even more important if this proposed rule is enacted. OSHA will be able to determine how injuries are occurring in the workplace, and use the submitted data to “identify emerging hazards, support agency response to those hazards, and target employers whose workplaces may include those hazards.” (Littler, 2022).
If you have questions regarding OSHA’s recordkeeping requirements or need assistance completing OSHA 300 logs, please contact the HRinDemand team.
- OSHA Recordkeeping homepage: https://www.osha.gov/recordkeeping
- OSHA Forms for Recording Work-Related Injuries and Illnesses, including Forms 300, 300A and 301: https://www.osha.gov/sites/default/files/OSHA-RK-Forms-Package.pdf
- OSHA list of certain high-hazard industries: https://www.osha.gov/sites/default/files/NAICScodesforelectronicsubmission.pdf
- OSHA Recordkeeping FAQ: https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.7
Bailey Cummins, PHR, is a member of the HRinDemand team, a human resources company in Reno, NV, offering expert guidance and easy-to-use tools to help small businesses with employment regulations, compliance, employee relations, and company growth.
Littler. (2022, April 4). OSHA Issues Proposed Rule on Improved Tracking of Workplace Injuries and Illnesses. https://www.littler.com/publication-press/publication/osha-issues-proposed-rule-improved-tracking-workplace-injuries-and?
United States Department of Labor. (2022, March 28). US Department of Labor announces proposed rule to amend federal occupational injury, illness recordkeeping regulation. [press release].https://www.osha.gov/news/newsreleases/national/03282022-0