Do not wait to electronically submit your organization’s 2016 OSHA 300A Summary of Work Related Illness and Injury form. OSHA’s long anticipated secure electronic submission website is currently live with a new submission deadline of December 1st, 2017.  The size and type of your establishment will determine if you must submit the OSHA 300A form and will also dictate what additional forms (300, 301) are required for submission in 2018. Regardless of size and industry classification, all employers under federal OSHA jurisdiction must report any work-related fatalities within 8 hours and any work- related hospitalizations, amputation and loss of an eye within 24 hours to the hotline (1-800-321-OSHA) or to your regional office or via the  serious event reporting online form .

What is an establishment according to OSHA?

OSHA defines an establishment as a “single physical location where business is conducted or where services or industrial operations are performed. A firm may be comprised of one or more establishments.” The number of employees in each establishment is determined by peak employment in the previous calendar year. Each employee is counted regardless of their work status as full-time, part-time, or temporary.  

What size and type of establishment must submit forms?

All establishments with 250 or more employees are required to submit the OSHA forms regardless of their industry classification.  Establishments with 20-249 employees in specific industry classifications (North American Industry Classification System -NCAIS) must submit forms. Generally, these are industries which have demonstrated higher rates of work-related injuries and illnesses. OSHA’s updated list of establishments fitting these criteria include hospitals, nursing homes, ambulatory care centers or inpatient treatment facilities.  

Fortunately, exemptions and partial exemptions exist for the OSHA recordkeeping rule. However, on January 1, 2015, an update eliminated a few industry classification exemptions.  The recordkeeping exemption continues for establishments with 10 or fewer employees for any industry classification. Partially exempt industry classifications  such as physician or dental offices, medical or diagnostic laboratories are not required to keep injury and illness records unless requested in writing by OSHA, Bureau of Labor Statistics or a state agency.  Previously listed as exempt, ambulatory care centers (6219 NCAIS) must now keep records and also submit the applicable forms electronically if the facility has 20 or more employees.

What should be recorded?

Not every work-related injury or illness should be recorded. If only first aid is necessary for treatment, this injury or illness should not be included on the OSHA forms.  The following is OSHA’s list of recordable injuries and illnesses:

  • 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 injuriesmedical removalhearing loss; and tuberculosis.

What software is needed and how much time will this take?
No special software is needed for the electronic submission process. OSHA will no longer accept any paper records. If your organization does not have internet access for data submission, OSHA recommends using free internet access such as in a public library. OSHA estimates that creating an account should take about 10 minutes and another 10 minutes to submit Summary of Work-Related Injuries and Illnesses (300A).  For 2018, the size of your establishment will determine how long the submission process will take. All forms (300A, 300 and 301) will be required to be submitted for establishments with 250 or more employees.  More time will be necessary to accommodate the additional requirement for submission of the Log of Work Related Injuries and Illness (300) and Injury and Illness Incident Report (301), estimated at 12 minutes per reported injury or illness.

Keep in mind that employees should know their right to report occupational injuries and illnesses and should never fear retaliation or discrimination for exercising that right!

 

For additional resource, click here  for the amended Regulatory Text for Recordkeeping Standard Part 1904.

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