Four-Step Injury and Illness Reporting Process
Once you’ve determined that you’re covered by OSHA’s recordkeeping requirement, you need to know the types of injuries and illnesses to record.
With the understanding that not all work-related injuries and illnesses apply, plan to record each injury and illness that:
- Is work-related
- Is a new case
- Meets one or more of the general recording criteria contained in the OSHA rules
The following four-step process can help you make the right decision:
- Did the employee experience an injury or illness?
- OSHA defines an injury as any wound or damage to the body resulting from an event in the work environment. Injuries include things such as a cut, fracture or sprain. It also includes an amputation, laceration, bruise, or chipped tooth. Illnesses include both acute and chronic illnesses, such as skin diseases, respiratory disorders, poisoning or hearing loss. You must also record all needlestick injuries (wounds caused by needles) or cuts from a sharp object that are contaminated with another person’s blood or other potentially infectious material.
The term “infectious materials” is defined in OSHA’s Bloodborne Pathogens standard and include such things as human bodily fluids, tissues and organs. If you are uncertain about whether an injury or illness occurred, you can refer an employee to a physician or other health care professional for evaluation, and consider the health care professional’s opinion when deciding to record the incident.
- Is the injury or illness work-related?
- According to OSHA, you should consider an injury or illness to be work-related if the work environment caused or contributed to the condition, or significantly aggravated a pre-existing injury or illness. OSHA defines the work environment as the establishment and other locations where one or more employees are working or present as a condition of employment. The work environment includes not only physical locations, but also the equipment or materials used by employees during the course of their work. Work-relatedness usually applies to an injury or illness resulting from events or exposures occurring in the workplace, unless an exception specifically applies.
The OSHA rules state that an injury or illness that falls under one of the following exceptions is not work-related and does not need to be recorded:
- At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than an employee. For example, an employee comes in on his day off to have lunch with another employee and trips and falls over a box. You would not have to record this injury.
- The injury or illness involves signs or symptoms that surface at work but result solely from a
non-work-related event or exposure outside the work environment.
- The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball or baseball. For example, an employee chooses to voluntarily participate in a blood drive and then passes out in the office. This would not be a recordable injury.
- The injury or illness is solely the result of an employee eating, drinking or preparing food or drink for personal consumption (whether bought on the employer’s premises or brought in). For example, if the employee is injured by choking on a sandwich while in the employer’s establishment, the case would not be considered work-related. However, if the gets sick from food contaminated by workplace contaminants (such as lead), or gets food poisoning from food supplied by the employer, the case would be considered work-related.
- The injury or illness is solely the result of an employee doing personal tasks (unrelated to employment) at the establishment outside of assigned working hours.
- The injury or illness is solely the result of personal grooming, self-medication for a non-work-related condition or is intentionally self-inflicted.
- The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work.
- The illness is the common cold or flu.
- The illness is a mental illness. Mental illnesses is not considered work-related unless the
employee voluntarily provides the employer with an opinion validating this connection from a qualified physician or licensed health care professional.
If it is not clear whether an injury or illness is work-related, do your best to evaluate the employee’s work duties and environment. The goal, ultimately, is to decide whether an event or exposure caused or contributed to the condition -- or significantly aggravated a pre-existing condition.
Traveling employees. OSHA states that injuries and illnesses that happen while an employee is traveling are work-related if, at the time of the injury or illness, the employee was engaged in work activities “in the interest of the employer.” This means that if an employee is traveling between customer contacts, conducting job tasks, or even entertaining (or being entertained) during the course of business and gets injured or ill – it would be considered a work-related incident.
OSHA has two exceptions for traveling employees. Injuries or illnesses that occur when an employee is on travel status do not have to be recorded if:
- They occur while the employee is on a personal detour from a reasonably direct route of travel (i.e., when an employee has taken a side trip for personal reasons).
- The traveling employee checks into a hotel, motel or other temporary residence. This means the employee establishes a “home away from home.” As such, you must evaluate the employee’s activities after he or she checks into the hotel or other temporary residence for work-relatedness in the same way you evaluate the activities of a non-traveling employee. When the employee checks into the temporary residence, he or she is considered to have left the work environment. When the employee begins work each day, he or she re-enters the work environment. If the employee has established a “home away from home” and is reporting to a fixed worksite each day, you also do not consider injuries or illnesses work-related if they occur while the employee is commuting between the temporary residence and the job location.
Employees who work from home. Injuries and illnesses that happen while an employee is working at home, including working in a home office, are considered work-related if the employee is performing work for pay, and if the injury or illness is directly related to that work (rather than to the general home environment or setting). For example, if an employee drops a box of work documents and injures her foot, the case is considered work-related. If an employee is injured because he trips on the family dog while rushing to answer a work phone call, the case is not considered work-related.
- Is the injury or illness a new case?
- Consider an injury or illness to be a “new case” if the employee:
- Didn’t previously experience a similar recorded injury or illness affecting the same part of the body
- The employee previously experienced a similar recorded injury or illness affecting the same part of the body but had recovered completely (all signs and symptoms had disappeared) -- but an event or exposure in the work environment caused the signs or symptoms of the previous injury or illness to reappear
- Does the injury or illness meet the general recording criteria?
- A work-related injury or illness must be recorded if it results in one or more of the following:
- Death. Deaths must be reported to OSHA within eight hours of their occurrence.
- Days away from work. Start counting the day after the injury, and include weekends and holidays.
- Restricted work or transfer to another job. Restricted work occurs when, as the result of a work-related injury or illness, you keep employees from performing one or more of the routine functions of their jobs, or from working the full workday that they would otherwise have been scheduled to work. Restricted work also occurs when a physician or other licensed health care professional recommends that employees not perform one or more of the routine functions of their jobs, or not work the full workday they otherwise would have been scheduled to work.
- Medical treatment beyond first aid. Medical treatment means the management and care of a patient to treat a disease or disorder. Medical treatment does not include visits to a physician or other licensed health care professional solely for observation or counseling; diagnostic procedures, such as X-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes; or first aid.
- Loss of consciousness. This is a recordable event no matter how long the employee is unconscious.
- A significant injury or illness diagnosed by a physician or other licensed health care professional. This includes work-related cases involving such things as cancer, chronic
irreversible disease, a fractured or cracked bone, chipped teeth or a punctured eardrum.
Reporting Fatalities, Hospitalizations, Amputations and Eye Losses
You must report all work-related fatalities, in-patient hospitalizations, amputations and loss of an eye to OSHA by telephone or online at osha.gov. For any fatality resulting from a work-related incident, you must report the event within 8 hours of learning out about it. For in-patient hospitalizations, amputations or loss of an eye, you must report the event within 24 hours of learning about it.
Here’s the information you’re required to provide:
- The establishment name
- The location of the incident
- The time of the incident
- Type of reportable event (i.e., fatality, inpatient hospitalization, amputation or loss of an eye)
- Number of employees who suffered the event
- The names of the employees who suffered the event
- Your contact person and his or her phone number
- A brief description of the incident
Be aware that in September 2014, OSHA made changes to the recordkeeping rule that expanded the types of severe work-related injuries and illnesses that all employers must report. OSHA previously required you to report only work-related fatalities and in-patient hospitalizations involving three or more employees.
The revised recordkeeping rule, which went into effect January 2015, now requires work-related fatalities to be reported within 8 hours, as well as all work-related in-patient hospitalizations, amputations and loss of eye within 24 hours.
Where to Record Injuries and Illnesses
You must use the OSHA 300, 300A, and 301 Forms, or their equivalent, to document recordable injuries and illnesses. You do not have to submit these forms to the government unless you are asked to do so.
OSHA Form 300
This is the Log of Work- Related Injuries and Illnesses. You enter information about your business at the top of the OSHA 300 Log and enter a one- or two-line description for each recordable injury or illness. It is used to classify work-related injuries and illnesses and to note the extent and severity of each case. The form asks you for the employee’s name, date of injury, a short description of the injury or illness and to classify the injury as a death, days away from work, job transfer or restriction, or other recordable injury.
You must keep a separate OSHA 300 Log for each establishment you expect to be in operation for one year or longer. That said, you may keep the records for an establishment at a central location as long as you can transmit injury and illness information between the two locations within seven calendar days -- and send completed records from the central location to the establishment within legal time frames when a government representative, employee, former employee, or employee representative asks you to.
It is also important to note that listing an incident on the OSHA 300 Log does not mean the employee is eligible for workers’ compensation or other insurance benefits. Listing the case on the log also does not mean that you were at fault or that an OSHA standard was violated.
Sharps Log vs. the OSHA 300 Log: The Bloodborne Pathogens standard (1910.1030) requires employers to maintain a log for all sharps injuries. Fortunately, you may use the OSHA 300 Log to meet this requirement as long as you enter the type and brand of device causing the sharps injury. You’ll also need to maintain your records in a way that separates sharps injuries from other types of work-related injuries and illnesses.
OSHA Form 300A
This form is the Summary of Work-Related Injuries and Illnesses that outlines all workplace incidents and time-lost information.
At the end of each calendar year, you must:
- Review the OSHA 300 Log to verify that the entries are complete and accurate, and correct any errors
- Use the Form 300A to create an annual summary of injuries and illnesses recorded on the OSHA 300 Log
- Certify the summary
- Post the annual summary in each establishment in a conspicuous place where employee notices are customarily posted. Make sure that the posted summary is not altered, defaced or covered by other material. Post it no later than February 1 of the following year and keep it in place until April 30. You must complete and post the form even if your company had no incidents during the year.
OSHA Form 301
This form is the Injury and Illness Incident Report, which goes into more detail about a specific incident. You must complete it for each recordable injury or illness entered on the OSHA 300 Log. It’s usually the first form you fill out when recording a work-related injury or illness.
There are situations where you cannot put the employee’s name on the OSHA forms for privacy reasons. For example, you cannot enter the name of employees for sensitive cases such as injuries or illnesses involving an intimate part of the body or reproductive system.
Instead of indicating an employee’s name, enter “privacy case” in the space normally used for the employee’s name. This will protect the privacy of the injured or ill employee when others see your OSHA forms. However, you must keep a separate, confidential list of the case numbers and employee names for privacy cases so you can update them and provide the information to OSHA if asked to do so.