Deadline for Reporting OSHA Records is Approaching

Here’s what you should do as you prepare OSHA records for annual reporting.

Most companies with more than 10 employees are required by Federal OSHA to maintain injury and illness records on a calendar year basis. In recent years, reporting requirements for electronically reporting illness and injury data changed the process significantly. Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries (includes construction and metal fabrication shops) with historically high rates of occupational injuries and illnesses need to electronically submit their 2021 OSHA data by March 2, 2022.

Reporting is done through a webpage available on the OSHA website. The Injury Tracking Application (ITA) is accessible from the ITA launch page, where you are able to provide your 2021 OSHA Form 300A information, which is a summary of your results for the prior year. Note that this document needs to be signed by an officer of the company. States with state-run OSHA programs (i.e., CA, OR, MI, etc.) have a similar form.

The requirements for recording an injury or illness on your OSHA 300 log can be complicated and companies should avoid “over-reporting” injuries that could lead to an over-inflated OSHA injury incidence rate. A company’s elevated OSHA incidence rate could impact future proposals and ability to work with certain clients so it is critical that your information accurately reflect the required entries.

Injuries should be recorded if they require medical treatment beyond first aid. For example, if an employee cuts a finger and receives “first aid” only (Band-Aid or bandage), then that injury is most likely not recordable. However, if the cut requires stitches (considered medical treatment), then it is recordable.

As a reminder, the OSHA 300A summary of 2021 recordable cases needs to be posted and available for employee review from February 1 through April 30, 2022. For more information on OSHA recordkeeping and posting requirements, go to the OSHA recordkeeping website.

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Mike McCullion, CSP, ARM, has over 40 years of occupational safety and health experience and previously served as director of market sectors and safety for the Sheet Metal and Air Conditioning Contractors' National Association. Having retired from the role at the end of 2021, McCullion now does safety consulting and writes for SNIPS.