Reporting injuries isn’t just a requirement. It’s also a roadmap to greater success.
What’s your go-to dinner party topic? Did you say, “OSHA reporting requirements”? Why not?
We probably ought to talk about OSHA injury reporting more often. After all, workplace violations continue to increase year after year. In addition to the human cost, such violations are ROI poison. And that’ll surely be a matter of interest to a roomful of your peers in the insurance sector.
Related: OSHA’s top ten violations of 2023 [slideshow]
OSHA’s regulations change—and theoretically improve—from time to time. This happened fairly recently, in fact. OSHA has long required employers to track and report worksite injuries. But as of January 1, 2024, the rules have changed—again. Employers must now observe the following additional requirements (all other reporting regulations regarding Form 300A still obtain):
- Establishments with 100 or more employees in certain high-hazard industries must electronically submit information from their Form 300-Log of Work-Related Injuries and Illnesses, and Form 301-Injury and Illness Incident Report to OSHA once a year. These submissions are in addition to submission of Form 300A-Summary of Work-Related Injuries and Illnesses.
- To improve data quality, establishments are required to include their legal company name when making electronic submissions to OSHA from their injury and illness records.
At some point, this may change, or be added to, or qualified in some way. But for now, this is how it is, so let’s discuss, in that light, what you need to know regarding OSHA reporting, and what you can do to streamline your reporting process.
What must you report?
OSHA requires employers to report “recordable injuries and illnesses.” They define 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 bones or teeth, and punctured eardrums.
- There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.
As a basic rule of thumb, recordable injuries are injuries requiring medical treatment beyond simple on-site first aid, which OSHA defines as:
- Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health-care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes).
- Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment); cleaning, flushing, or soaking wounds on the surface of the skin.
- Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment).
- Using hot or cold therapy.
- Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
- Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, backboards, etc.). Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister.
- Using eye patches.
- Removing foreign bodies from the eye using only irrigation or a cotton swab.
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means.
- Using finger guards.
- Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes).
- Drinking fluids for relief of heat stress.
And in terms of how swiftly one must report recordable injuries, OSHA is quite specific: “Employers must report any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization of a worker within 24 hours.” In said reports, employers must note the following:
- The location of the incident;
- The date and time of the occurrence;
- The status of the injury; and
- Other details that explain what happened and how it might be avoided in the future.
Employers must also report near-miss incidents. A near-miss incident is when serious injury almost occurs but doesn’t, based more or less on luck. Reporting such incidents tells a fuller story about a workplace’s relative hazardousness.
Related: What happens during OSHA inspections?
How does OSHA reporting work?
OSHA reporting is fairly simple. Here’s a step-by-step how-to:
First, set up an Injury Tracking Application (ITA) account. Your ITA account must be connected to the same email address as your Login.gov account.
You can then submit these three forms electronically:
- OSHA Form 300A Annual Summary
- OSHA Form 300 Log
- OSHA Form 301 Incident Report
in one of these three ways:
- Using the ITA webform to manually enter your data.
- Uploading a CSV file to the ITA.
- Using an application programming interface (API) feed to transmit data electronically.
Take note: Your report is due March 2 of the calendar year following the year from which such information was gathered.
Who is exempt from OSHA reporting?
Under certain circumstances, you may not have to submit regular injury reports to OSHA. The following are exempt from OSHA reporting:
- Businesses with 19 or fewer employees.
- Certain low-risk services such as shoe stores or florists.
- Businesses employing between 20 and 249 employees that are not listed in Appendix A to Subpart E form, which includes the agriculture, construction, manufacturing, and freighting industries, among others.
How to streamline your OSHA reporting
There are many different types of OSHA reporting software. These vary in quality and price by industry, and some find them useful. But arguably just as useful is having a computer around—that is, create your own easily traceable database in a Word or Excel doc that is less liable than a stack of papers to blow away or get lost.
But when it comes to streamlining OSHA reporting, an ounce of prevention is worth a pound of cure. That may seem anticlimactic. But there are no good shortcuts—no legal ones. Reporting is reporting is reporting. One can be patriotically glad that such requirements exist or flummoxed by the presence of such “intrusive” legalities, but it is what it is, and it’s better to get things right from the start.
Here are some ways you can avoid unnecessarily onerous OSHA reporting year after year.
Track everything
Tracking near-miss incidents as well as minor incidents requiring no more than first aid fills out the picture you’re painting with your overall safety report. This will help tell you where to focus in terms of hazard elimination. A non-serious injury today could be a life-threatening one tomorrow.
Train everyone
Make sure you have appropriate safety training in place. Such training shouldn’t be allotted to management alone with the expectation that they’ll pass it on to everyone else. Make sure every employee is part of the training process. That way nothing will get lost in translation.
Don’t ignore complaints
Whistleblowers are a more common workplace feature than ever. That signals that employee complaints regarding safety conformance are being ignored—or even flagrantly violated. A well-run, transparent company, even one abounding in dangerous worksites, staffed by conscientious managers, obviates the need for whistleblowers.
Related: How to uphold OSHA’s standards with 4 pillars of health and safety compliance
OSHA reporting final thoughts
Compared to other government documents, OSHA reporting forms aren’t terrifically onerous. There are relatively few forms involved, and you can submit them electronically. Filing one’s taxes is often more complicated and time-consuming.
The Platonic ideal of a workplace is one where injury is impossible—hence resulting in nothing at all to report. But in many industries, that’s a pipedream. It’s best to be prepared for what one should think of as inevitabilities rather than contingencies, and know ahead of time what must be done about them.
In other words, when someone brings up OSHA reporting at your next after-hours soiree, ignore the sighers and groaners: Dive in, and learn how to improve what you’ve been doing poorly and perfect what you’re already doing right.