Navigating OSHA Recordkeeping & Reporting

Hello everyone, it’s very important that your company’s OSHA logs are inspection ready and that you understand the key dates for reporting requirements.

Today we will provide you with the clarity and tools needed to accurately document work related injuries and illnesses, satisfy upcoming reporting deadlines and provide best practices for compliance.

On behalf of McGriff, I would like to take this opportunity to thank each of you for joining us today as we discussed navigating OSHA record keeping and reporting.

My name is Lesonya Wilder and I will be your host for the call today.

There are just a couple of housekeeping points that I would like to share with you before we get started.

This is a live session and you are in listen mode only.

If you have any questions at any time during the presentation, feel free to utilize the chat box to type in your questions and we will address them during our Q&A segment at the end of the presentation.

If time doesn’t permit us to answer all of your questions after the presentation, we will be sure to capture them and provide the responses afterwards.

Now it brings me great pleasure to introduce to you our speakers for the hour.

We have our very own George Harris, a risk Control consultant with McGriff who works closely with his clients to evaluate risk exposure and develop strategies, processes and safety programs to reduce their total cost of risk.

An industry veteran since 2009, George worked with clients in the manufacturing, logistics and construction industries and consults with clients on environmental exposures and controls.

He is passionate about safety, leadership and culture.

We also have with us today our very own Kevin Ferguson, a Risk Control Manager with McGriff.

Kevin is an industry veteran since 2003 and his expertise include construction, manufacturing, ergonomics and fleet safety.

So without further ado, I would turn it over to George to kick off the presentation.

Good afternoon, everybody, and thank you, Lasagna.

Welcome, everybody.

 

It’s that time of the year and William McGriff wanted to host his webinar in January to provide some guidance, assistance and resources for an OSHA requirement that can be confusing and cause a bit of anxiety, which is OSHA record keeping.

Here we come.

Today we’ll be presenting information on five key areas, which are the OSHA record keeping basics, some guidelines and deadlines, severe injury reporting, and then finally some resources to assist you with the OSHA record keeping requirements.

So let’s begin with the basics.

So the basics of OSHA record keeping focus on a few areas #1 which organizations are required to record keep and then who is exempt?

What injuries and illnesses are you required to record based on your OSHA criteria?

And then how do we protect the privacy of the injured and how long do you keep those records?

So if you are required to keep records, this begins essentially with companies or establishments that have 10 or more employees at all times during the record keeping calendar year.

Most industries must record keep industries injuries.

However, certain industries such as retail establishments, educational institutions, and financial services are not required and are therefore exempt.

There is no exemption, however, for the reporting of severe injuries, which we’ll discuss a little bit more in detail in the webinar.

And then finally, certain regulated industries such as mining and nuclear power are exempt because they fall under separate safety protocols.

And then something of note, OSHA can require exempt employers to complete a statistical survey, which is sent by the Bureau of Labor Statistics.

So often there’s a couple of critical questions that are that are asked about record keeping.

Number one, on whose log is the injury or illness captured?

And then #2 is the injured illness or illness actually a recordable?

So on the left you’ll see the answer to the first question.

And essentially it’s based on who provides the day-to-day supervision.

So an example below it shows that if you have a general contractor and there’s A and they provide the day-to-day supervision to that subcontractor.

The general contractor must record any sub injury or illness on their log.

And then on the right you can see a flow chart that asks questions about when the injury, when or where did the injury occur, was it work related, was it new and then does it meet the general recording criteria.

If you answer yes to those questions, then it is considered a recordable.

And so often the question is well, what’s the general recording criteria and we’ll discuss that on the next slide.

So we talked about the last question, what is actually a recordable and it begins with requiring that the injury illness being treated is beyond first aid.

So if a medical treatment beyond a first aid for an injury illness, then it’s considered a recordable.

So keep in mind that a visit to a healthcare professional such as a physician does not automatically mean that the injury or illness is a recordable.

So you can go to the doctor and the doctor can perform first aid and return employee back to work and then it becomes just the first aid.

It’s not considered a recordable.

And in many cases, a good return to work program can mitigate or even prevent recordables.

So some other criteria that’s just as important and automatically designate an injuring illness as a recordable.

If there’s a death, if there are days away from work from the injuring illness, if there’s restricted work or transfer to another job, if an employee loses consciousness due to an injuring illness or there’s a significant injury or illness that’s diagnosed by physician.

If there are some, there’s some other conditions that are require special recording consideration #1 anything that involves needle sticks or sharps, medical removal, hearing loss, and then finally infectious disease such as tuberculosis.

So for some clarity, let’s review some common first aid criteria that’s determined by OSHA.

At the top you’ll see a pretty common one, the use of non prescription medication at non prescription strength.

And the best example is Tylenol 500.

That’s the highest level you can get over the counter.

The next one will be the administering of a tetanus immunization.

The next one would be the use application of a bandage such as a Band-Aid or a butterfly bandage.

The use of hot and cold therapy for sprain and strain.

The use of a non rigid means of support such as a a non rigid back brace and then the use of a splint or a sling.

The removal of a a splinter or other form material from the eye using eye wash or a cotton swab.

And then at the bottom you’ll also see massage can be used is also considered first aid.

However, if that massage is part of physical therapy or is chiropractic treatment, then it’s considered a recordable for worker keeping purposes.

And then finally drinking fluids for the relief of heat stress.

And then just as a reminder, first aid treatments are not considered OSHA recordables.

And if the event is recordable, let’s look at some of the forms that you’ll be required for record keeping.

So the first form is the OSHA 300 log and it lists the individual cases along with the injury or illness description.

So if you start at the at the far left, you’ll see that it asks you to identify the person.

You have a case number, the employee name and their job title.

In the next section, you have the date where the injury and illness occur and in a brief description of the injury or illness and then in the middle it asks you to classify the case, whether it’s a death days away from work or other job or job restriction or other case.

In this case, you should only select one of these, one of these boxes so that it doesn’t affect your record keeping counts on your OSHA 300, a summary.

And then next to that, you’ll have a column that asks you to calculate the total number of days away from work or any job transfers or restrictions.

And then the last column to the right, it asks you to check the injury or illness for for the log.

Again, just a reminder, select only one of those injury or illnesses and this avoids any discrepancies on your OSHA 300A.

And then the second form is OSHA form three O 1, which is completed on each individual recordable case.

That’s the term about OSHA record keeping criteria.

So this is where you’ll detail all the injury and illness information is placed.

So keep in mind this is confidential information and should be treated as such.

So note you don’t have to actually use the OSHA 3 O one form.

However, the information that’s captured here should be part of your incident investigation program.

And if you don’t use the OSHA form three O 1, you should still maintain your incident records for at least five years as part of your record keeping program.

And in some cases, there’s certain injuries and illnesses that require special handling, which we’ll discuss next.

So under certain circumstances you have what is called a privacy case that’s required from such circumstances as sexual assault, mental illness, infectious disease such as tuberculosis, needle sticks or sharps from blood borne pathogens and other illnesses or situations where an employee voluntarily asked to their name not be entered onto the OSHA 300 log.

So it’s imperative upon you as as the company to make sure that their privacy cases are handled with care.

And on the OSHA 300 log, you’ll simply remove the employee’s name and title it as privacy case and you’ll maintain separate files for that individual, individual case.

And then just a reminder, the OSHA 303 O one and three 300 A are retained for five years at the end of the calendar year it covers.

And since we covered the basics of OSHA record keeping, let’s talk about reporting deadlines and in criteria for OSHA records, so annual posting and submission requirements that can vary by employer size and even industry.

So it’s also important to ensure that these deadlines are met, and we’ll talk about those shortly.

So the table shown here kind of outlines the record keeping requirements and deadlines.

So you have 4 record keeping categories based on the number of employer employees and then also the industry.

So certain industries such as retail establishments, educational institutions, and financial services are not required to record keep.

However, they may be surveyed, surveyed by OSHA or the Bureau of Labor Statistics for an injury survey and you’re required to respond to these.

So the first category on the left is for companies with 10 or fewer employees for the entire prior year.

Note that they are exempt from record keeping.

So the next category is for employ establishments with 11 to 19 employees and then you have 20 to 249 employees and you have 250 plus employees.

These next three categories, they all are required to maintain OSHA records for injuries and illness unless they are exempt as we’ve noted before, and they may be and those that are exempted based on those establishments are still subject to a injury survey from OSHA or the Bureau of Labor Statistics.

They’re all required to maintain their OSHA 303 O 1300A forms for five years.

They’re all required to post A300A from February 1st to April 30th.

And then if you note further to the right employees, establishments with greater than 20 employees, they have an additional requirement to electronically submit their OSHA record keeping information.

And this is via the ITA portal, the entry tracking application and we’ll discuss that a little bit later and in the submission deadline for electronic submission is March 2nd.

And then of note, if your company or establishment is in the state plan state, ensure your company or establishment follows the state plan state requirements.

So in locations such as California, Oregon or South Carolina, there may be some some different requirements and you want to make sure that you are aware and comply with those.

So if your company or establishment is required to record, keep posting that ocean 300 A is a critical action that has must be completed on February 1st.

300 A is essentially a summary of your courtable cases, days away, injury and illness types and then establishment information.

So essentially everything that was on the 300 log gets summarized on the 300A and it’s posted for employees and the public to see.

So the 300 A is is posted for the previous year.

So this year’s 2026, you’ll be posting for 2025.

And again, making sure it’s located in a conspicuous location such as a break room or bulletin board.

And even if your establishment or company has 0 cases, you’re still required to post the 300A.

And finally, ensuring that the form is signed by the appropriate party in this case would be a company executive or the senior person at that establishment.

So this is a screenshot of the actual OSHA Form 300A.

And if you notice to the left, you’ll see at the top you’ve got the number of cases, calculation of total number of days away, away from work or restricted, and then a calculation of the injury or illness types at the bottom.

And then at the right you’ll see the company information.

You’ll provide the establishment name, the actual address location, the industry you’re located in.

And if you’ll also see in the middle, it asks for the NAICS code.

And if you don’t know what the your next code is, you can always go and do a Google search based on your industry and then it will provide you with that number.

And then finally, it asks for the employee employment information, the average annual number of employees at that establishment and the total number of hours worked, which you can obtain from human resources.

And then finally the signature for the company executive or official.

So we talked about the additional reporting requirement for electronic submission.

So for those establishments we discussed that have 20 to 249 and 250 plus employees, this is the second requirement which is the electronic submission of those forms via the ITA portal.

Ensure that you check the ITA portal for your compliance requirement because again, it’s it’s based on establishment size as well as your industry.

And so there’s a couple of additional specifications.

So you only submit the the 300 A only if you have 250 or more employees and if you’re in an exempt industry such as retail, educational institutions and financial services, you do not have to post electronically.

If you have 20 to 249 employees and you’re performing construction, manufacturing, operating a grocery store, performing trucking or nursing care services, you are required to submit the 300A.

And then if you are in construct, I’m sorry, logging, confectionery production, sawmills or bakery and you have 100 or more employees, you’re, you’re required to submit not only the 300A, but you also have to submit the OSHA 300 and the three O 1 as well.

So for those who are required to submit electronically, this is essentially a a flow chart that shows whether or not you are required to submit electronically.

And this can be a bit confusing.

However, the ITA portal does have a verification tool where you can input the number of employees that your establishment, what industry you’re in, and location, and it will confirm whether or not you are required to submit records electronically.

So for those that are required to electronically submit, this is a screenshot of the ITA portal.

So this system requires a login.gov credential for secure access and you can establish 1 central login to manage the electronic submission for all establishments.

So if you have a login.gov credential, you can create a new ITA account and utilize the login.gov credentials there.

As you see in the middle.

If you don’t have login.gov credentials, you can create a login.gov access at the very top and you can create your IT account with the new login.gov credential.

So once you login with your login.gov credentials, you you go to the application home and you’ll see at the top where it says manual, manual data industry.

This is for you to manually enter all of your OSHA record keeping information.

If you’re required to submit electronically.

The next option is for mass upload via CSV file.

And essentially it requires you to input all of the information from your 303 O one and three 300 A, such as your injury and illness data and then company and establishment data.

And then you’ll just upload the CSV file in the batch upload.

So the importance of electronic record keeping goes back to 2017 when OSHA establishes requirement with the intent of creating additional transparency, data accuracy and a better understanding of workplace, workplace hazards.

So several reasons why submitting these records are important.

Number one, your OSHA records become public on the Bureau of Labor.

Statistics website OSHA can target resources to reduce, eliminate, and prevent workplace injuries, and then additionally, insurance carriers utilize ITA data to establish workers compensation premiums in certain circumstances.

OSHA requires immediate reporting of a case based on the severity of an injury or an illness, and we’ll talk about that in this next section.

Any circumstances an employee must, an employer must report to OSHA within a certain time frame, and this is regardless of whether the company or establishment is exempt from record keeping.

So if you have a fatality, it must be reported within 8 hours.

If there’s an inpatient hospitalization, amputation, or eye loss, it also must be reported.

They all must be reported within 24 hours of the event.

There’s three ways you can make a report to OSHA of either fatality or a hospitalization, amputation or an eye loss.

You can call your nearest OSHA office, you can call the OSHA 24 hour hotline, or you can report online.

Keep in mind that if you use any of these three reporting methods, you’ll be required to provide information about the business, the name of the employee, the location and time of the incident, a brief description of the incident, and then a contact person so that OSHA can get in contact with you about any investigation or follow up about the event.

So reportables apply again regardless of company establishment, size or industry.

If there is an injured or I’ll employee is formally admitted, also known as a hospitalization.

This must be reported.

Observations for testing are not required to be reported if a part of a limb or an external body part is lost to trauma.

Examples include fingertips, hands or feet or medical amputation or reattachment.

A report must then maybe to must be made to OSHA.

There’s some events not considered amputations such as scalping or the OR broken teeth.

So the employer providing the day-to-day supervision is responsible for notifying OSHA of the reportable, just as the same as with recording a workplace injury.

So keep in mind that a reportable is still captured on the OSHA 3303-O1 or the 300A as a recordable injury or an illness.

In some cases, there are some severe injuries that are not required to be reported to OSHA.

So for example, if you have a fatality that occurs 31 days after a work related injury or an illness, or if there’s an amputation, hospitalization, loss of an eye that occurs more than 24 hours after work related injury and illness, then they do not have to be reported to OSHA.

They should be recorded unless it’s in a work construction work zone.

A motor vehicle accident on a public St.

A highway does not need to be reported.

If you’re traveling by commercial plane or bus and, or and sustaining injury and illness, it does not need to be reported.

If you’re hospitalized for any diagnostic testing or observation in the hospital does not need to be reported.

And again, just a reminder that if you’re not subject to OSHA that you should and under a state planned state that you were to confer with those local requirements because there may be some distinctions that you need to be aware of and make sure you follow their regulations.

So as OSHA record keeping can be confusing and a bit distressing, we provided some best practices for your company or establishment to follow.

So OSHA record keeping is a it’s a critical piece of the EHS and Risk Management program.

These records are discoverable in legal matters and can be requested for by OSHA for up to five years.

And because of this, it’s important to ensure that there’s consistency in how injuries and illnesses are recorded.

So responsible staff should be trained to ensure procedures are followed and files are maintained.

Conduct routine audits and reconciliation of your files to ensure that any discrepancies or gaps are addressed.

And then finally, there’s many tools available online to assist with any record keeping, and we’ll talk about a few of those shortly.

Maintain the confidentially confidentiality of any injured or I’ll employee by limiting access to files and in providing training about training for those who be handling on on privacy of these cases.

And then finally, make sure you maintain both electronic and physical copies.

Number one is establishes a level of redundancy and is also required such as the 300 a which is to be posted physically and then also maintains maintain backup files.

So McGriff has available to their clients some great tools, assist with OSHA record keeping and I’ll be turning this presentation over to Kevin Ferguson to discuss.

All right, thank you, George.

That was some great information on, yes, a challenging and confusing topic sometimes.

So we do want to make sure that you know, you are aware of multiple resources we have to assist with this topic.

The first I want to mention was our tool called McGriff Resource Net.

This is an online portal that you as a McGriff client have access to that houses all kinds of guides and tools on this topic.

And a good example of that is our OSHA record keeping and reporting guide.

This guide has all the information that’s been shared in this PowerPoint as well as more details about very specific nuances within the OSHA record keeping space.

So feel free to ask your risk control consultant or your client service team for access to that specific guide or access to McGriff Resource Net as a whole.

We also would like to invite you to attend our annual OSHA update webinar that we conduct in June.

This will be held June 18th this this coming year at 2:00 PM.

And on this webinar, we’re going to talk about current rulemaking information that OSHA has is being considering and also cover OSHA emphasis programs, certain industries that they are targeting for compliance.

So we definitely want you to you know, sign up and register for that webinar as well.

And then lastly, we have some helpful links here that will kind of just give you more information about this topic.

The first one there is to Osha’s overall record keeping standard.

The second one covers those industries that are in low hazard classes that are exempt from record keeping.

We also have a link to report the severe injuries that George mentioned.

And then two links that help you determine, OK, do I even need to go down this road of electronic submission so that that ITA determination tool really help you, will really help you decide, you know, again, based on your employee size and industry, do you have to do the electronic submission?

The IPA reporting link is there for you so you can go straight to that application.

We have a link for the state plans.

Again, most state plans are going to fall right in line with the the federal requirements for record keeping.

I know Minnesota does have a couple additional requirements there.

And then lastly, is is a great source for all the different nuances and questions that can come up with this record keeping rule.

So it’s an FAQ document that probably has over 100 different scenarios that you can read through, such as, you know, what if, what if an employee resigns after you know, they’ve had an injury and you know, they’re still out of work?

How do I count the days for that or, you know, do I count weekends on when I’m recording lost days?

All these type of very specific questions are covered in those FAQ documents.

And even now in the world of, of AI, trying to find answers to some of these, it’s, it’s getting, you know, easier and easier to find those answers.

But you know, our McGriff team is here to, you know, help you out through this process.

So, you know, never hesitate to reach out to, you know, someone on your McGriff team for help.

So with that lasagna, were there any questions in the chat box?

Absolutely.

First of all, thank you, George and Kevin for that wonderful presentation and that valuable information.

With February right around the corner, I’m pretty sure this was helpful for everyone on the call and we do have some questions that have come through.

If you have additional questions, feel free to utilize the chat box or the Q&A box and we will entertain those questions at this time.

So the first question that we have, it says if your company has a private entry, do you still show the entry on the OSHA 300 as no name but privacy of the confidential form?

Yes, the the name would not go on the OSHA 300 log and you would write privacy case instead of the employee’s name in that situation.

OK thank you.

The second question is what if an employee was put on work restriction then returned to work with no restrictions.

The employee then re aggravated the injury and then had days away from work?

Does days away from work and job restriction columns on step three both get checked?

Yeah, that’s one of those very nuanced situations.

I think we’re going to need to do a little bit more research on lasagna.

So yeah, just make sure we’ve got the the contact information and we’ll do some more research on that.

All right.

But yeah, I think I think that would apply in this case.

But let me let’s let’s just do some more research and and confirm that.

All right.

Sounds good.

The next question says our HR professional that has submitted the OSHA 300 with an ITA account has now left the company.

How can I get access to our company account?

I can answer that there is a there is a help desk for the ITA portal.

Best recommendation is to contact that help desk if they if they did not, if you know what their employees e-mail address or whatever they were using that will probably be very helpful.

I actually dealt with a scenario like that where they didn’t leave but the person who was administering the site passed away and the company had to go through the go through the help desk and regain access.

OK, thank you.

Next question, if one of our drivers semi truck was rear-ended and diagnosed with strain of cervical muscle and lumbar due to the motor vehicle collision, would it be recordable?

So the key there, let’s sign is if the incident happened in a construction work zone.

If it if it did, it would be recordable.

But if it just happened on a normal highway that’s not within a construction zone, then they would not have to put that on their log.

Awesome.

And I did get a several questions regarding the handouts and the recording.

And they said it was on the Interstate.

Yeah.

As long as it was not in a construction zone, it would not have to be recorded.

OK.

Thank you.

Everyone will receive a copy of the presentation slides as well as the recording of this session.

And so that’s all of the questions that we currently have in the box.

Of course, if additional questions occur once you get off the call, you will have George and Kevin’s contact information and you can feel free to reach out to them with any additional questions that you have.

So again, on behalf of McGriff, we would like to take this opportunity to thank each of you for joining us and we hope you have a wonderful rest of your day.

Thank you.