The time has come to submit your injury and illness summary records to OSHA, but are your records up to date and accurate? In the first two installments of our 3-part series on OSHA recordkeeping, we covered the “who" and “how” in OSHA Recordkeeping: Who, How, What, When and Why? Oh My! and “what,” in New Year, New OSHA Log. In this final installment, we will address the “when” and “why” questions of OSHA recordkeeping.

The "When"

Many questions arise regarding the timing of recording, updating, and submitting your OSHA records.

If OSHA requires your establishment to complete the OSHA 300 log, you must record the incident within seven (7) calendar days of when the employer was notified of the recordable injury or illness. At the time the log entry is made, the employer must record the expected number of days the employee is out of work and/or works restricted duty, and then update the log when the actual number of recordable days is known. 

Many ask, “Do I start the lost workday count on the day of the injury or illness?” The answer is, “No.” The lost workday count begins on the day following the injury or illness.

Another question asked by employers is, “What do I do if the injury happens in one year and lost time extends into the following year? Do I have to log the injury in both years?” The answer is, “No.” The injury should only be entered on the OSHA 300 log for the year in which the injury or illness occurred.

Other “when” questions arise regarding the maximum lost workdays to be counted by an employer. The answer is a maximum of 180 days. It should be noted that the number of workdays lost includes all calendar days the employee was unable to work, not just the employee’s regular workday schedule.

The last “when” question is, “When and what do I have to submit to OSHA?” The answer is not the same for all employers.

If OSHA requires your establishment to complete the OSHA form 300A Summary and has 250 or more employees, you must submit the required information from the OSHA 300, 300A and 301 forms by March 2nd of the year following the year the information was entered on the log (March 2, 2024, for information gathered in 2023).

If your establishment had more than twenty employees but less than 250 in certain industries listed in 1904 Subpart E Appendix A, you must submit your information on the OSHA 300A Summary to OSHA by March 2nd of the year following the year the information was entered on the log. (March 2, 2024, for information gathered in 2023).

Effective January 1, 2024, establishments with 100 or more employees in certain high hazard industries will also have to submit their OSHA 300 log, OSHA 300A Summary and OSHA 301 forms by the March 2nd deadline of the year following the year the information was entered on the log (March 2, 2024, for information gathered in 2023). These “high hazard” industries can be found in 1904 Subpart E Appendix B.

All information submitted to OSHA must be done using the Injury Tracking Application (ITA) link that can be accessed through www.osha.gov.

The "Why"

The question of “why” we do this should go beyond legal reasons or to prevent a citation. The real “why” employers should comply with these regulations is to prevent injuries and illnesses from affecting their most valuable resource—their employees.

In this series, we have covered who, how, what, when and why of recordkeeping. The best source of information is directly from OSHA, but you can also request assistance from your MEMIC safety management consultant and your insurance agent. 

MEMIC policyholders can register for our OSHA Reporting & Recordkeeping webinar on January 31, 2024, at 10 am (EST) to gain valuable insights and ensure compliance with expert guidance. Don't miss out - secure your spot now!