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CONN-OSHA Quarterly

Volume No. 27
Fall 2001

Revised OSHA Recordkeeping Requirements

Joe Weber, Research Analyst Supervisor

Injury and illness records are critical indicators - for employers, for employees, and for the Occupational Safety and Health Administration (OSHA). They indicate how we're doing in our efforts to keep workers healthy and safe. They pinpoint weaknesses, breakdowns in machinery, inadequate personal protective equipment, failures in communication, and insufficient training. When a worker gets sick or hurt, something has gone wrong. Employers need to look at these cases to see if they can take action to prevent future problems. But there is also great value in reviewing the records as a whole to identify patterns and trends. What's happening in specific departments and across the facility? How does your injury and illness experience stack up against others in your industry? Is it clear that your employees understand the need to wear protective equipment and follow safety rules? Asking these questions and taking action in response to the answers can prevent future injuries and illnesses and improve a company's bottom line.

Whenever OSHA visits a workplace, injury and illness records are the first item the inspectors want to see. These records give them a starting point to identify where problems may lie. Of course, if an employer has been tracking its experience and addressing these issues, what is found is that the site has corrected hazards and resolved concerns.

Records are important beyond individual establishments. We need to know how we're doing collectively - the entire U.S. workforce. We need to find out where the problems are so we can work to address them. The Bureau of Labor Statistics (BLS) surveys about 200,000 employers of all sizes and in all industries to develop the national estimate of workplace injuries and illnesses issued every December since 1971. These statistics chart the magnitude and nature of the occupational injury and illness problem across the country. Congress, OSHA, and safety and health policy makers in Federal, State and Local governments use the BLS statistics to make decisions concerning safety and health legislation, programs, and standards. Employers and employees use them to compare their own injury and illness experience with the performance of other establishments within their industry and in other industries.

Effective Date: January 1, 2002

OSHA's new recordkeeping requirements will take effect on January 1, 2002. The new rule simplifies the recordkeeping system for employers. It's easier to determine what must be recorded, and the forms are simpler. The new rule also gives employers more flexibility to use computers for recordkeeping. And it provides greater privacy protection for employees.

The new OSHA 300 forms will be available soon on the agency's website at on the recordkeeping page. Printed forms will be available from OSHA Publications late this fall. OSHA is currently developing an extensive outreach and training effort to help employers make the transition to the new recordkeeping system. There will be satellite classes, fact sheets, a brochure, an E-Tool and more. Check the OSHA recordkeeping page on the web.

OSHA has required employers to keep injury and illness records since 1971, the year the agency was formed. This is the first major effort to improve the system established 30 years ago. OSHA's recordkeeping rule requires about 1.4 million workplaces to record work-related employee injuries and illnesses. Smaller employers with Published by the Connecticut Department of Labor, Project Management Office or fewer employees are exempt from most recordkeeping provisions. So are employers in a number of low-hazard industries in the retail, service, finance, insurance and real estate sectors. States, such as Connecticut, that operate their own job safety and health programs will be adopting comparable recordkeeping rules that will also be effective January 1, 2002. The State of Connecticut Department of Labor, Division of Occupational Safety and Health (CONN-OSHA) program covers the public sector workforce in state and local government operations. States must have the same requirements for which injuries and illnesses are recordable and how they are recorded. However, other provisions, such as industry exemptions, may be different as long as they are as stringent as the federal requirements.

Unresolved Issues

There are currently two issues that remain unresolved. These are hearing loss and the definition of musculoskeletal disorders (MSDs). Earlier this year, on July 3rd, OSHA proposed delaying for one year implementation of the criteria covering work-related hearing loss. There would also be a one-year delay for the definition of musculoskeletal disorder and the requirement to check the MSD column on the OSHA injury and illness log. Comments on these proposed delays were due on September 4, 2001. If the agency proceeds with the proposed delays, the 300 logs may be revised for 2002 to delete the columns for MSDs and hearing loss. During the proposed delay, OSHA will reconsider what level of hearing loss should be recorded as a "significant" health condition. The proposed delay for the definition of musculoskeletal disorder is in line with the Labor Secretary's plan to develop a comprehensive approach to ergonomics. One of the issues to be resolved is the appropriate definition for "ergonomic injury" and "musculoskeletal disorder." The delay would enable the agency to develop appropriate definitions consistent with those chosen for the ergonomics effort.

In revising the rule, OSHA had the following goals: improve the data, make recordkeeping simpler for employers, maximize the use of computers and technology, improve employee involvement and protect the privacy of the injured or ill worker. Here are some of the highlights of the new Recordkeeping Regulation which will go into effect in January:

Who Must Keep Records?

  • When it comes to OSHA recordkeeping, the first question an employer needs to ask is: Am I covered? Every employer, regardless of size or industry, must report any incident that involves the death of a worker and/or the hospitalization of three or more workers. You must call your local OSHA office or 1-800-321-OSHA within eight hours. You don't have to report most highway or commercial carrier accidents, but you must report fatal heart attacks.

  • If you have Published by the Connecticut Department of Labor, Project Management Office or fewer workers, you normally do not need to keep injury and illness records. Remember to include temporary employees under your direct supervision in that count. This size exemption is based on the number of employees in the entire company, not the individual site, establishment or division. And if you're in one of the exempt low-hazard industries, you don't have to keep records unless OSHA or BLS asks you to participate in their annual surveys. You'll find a complete list of exemptions by Standard Industrial Classification (SIC) code in Appendix A of the rule.

    So what do you actually record?  Injuries and Illnesses that result in:

    • Death

    • Days away

    • Restricted work activity or light duty

    • Transfer to another job

    • Medical treatment beyond first aid

    • Loss of consciousness

    • Significant injury or illness diagnosed by a physician or other licensed healthcare professional

  • The injuries and illnesses you record must be new cases that are work-related. That includes pre-existing conditions that are significantly aggravated by workplace events or exposures. There’s also a new list of exceptions - cases not considered work-related. The rule makes it clear that employers don't have to record cases involving eating and drinking food and beverages, common colds and flu, blood donations and exercise programs. But some injuries to employees doing work at home or while traveling on business are counted.

  • Employers need to record all injuries from needles and sharps that are contaminated by another person's blood or other potentially infectious material, not just those that lead to illness. They'll also record a case for any worker removed from work under the provisions of an OSHA standard, such as lead. The new rule also has instructions for recording work-related cases of tuberculosis.

  • What you don't record are injuries or illnesses treated through first aid, such as taking aspirin, getting a tetanus shot, applying a butterfly bandage, draining a blister, wearing a finger guard, etc. For recordkeeping purposes, first aid doesn't make a case recordable.

  • It will also be simpler when it comes to counting days away from work or days of restricted work activity - just count calendar days. This will make the counts more consistent and make the actual length of an injury or illness clear.

New Forms

  • There are three: the 300 log, which replaces form 200; 301, which replaces Published by the Connecticut Department of Labor, Project Management Office1; and 300A, a separate form to use to display the annual summary.

  • The 300 log is simpler and smaller. It now fits on legal-size paper so you can download it directly from OSHA's website and print it out in your office. Your 300 log is a listing of all the injuries and illnesses at this site. You can maintain it on a computer or at another location as long as you can produce a copy at the workplace whenever it's needed. You have seven days to fill in the form once you learn of a case.

  • The 301 form is the individual record of a work-related injury or illness. You'll fill out a new form for each case, again within seven days. You can use an equivalent form if you prefer.

  • Form 300A is the summary of work-related injuries and illnesses. This is the one you post every year. The new rule requires a three-month posting: February 1 to April 30. The summary must be certified by a company executive: the owner, an officer of the corporation or the highest-ranking company official working at that site or his or her supervisor. Top management needs to be aware of the injury and illness experience of the site and verify that the records are accurate.

  • OSHA recordkeeping forms must be kept for five years following the year they cover. During that time, you need to update the OSHA 300 form to include newly discovered cases or to show changes in old cases. You do not have to update the 301 and 300A forms. Be sure to transfer the recordkeeping forms if you sell your business.

Employee Access and Privacy Protections

  • With the new forms come new privacy protections for workers. You won't enter the name of workers for sensitive cases such as injuries or illnesses involving an intimate body part or the reproductive system, sexual assault, HIV or hepatitis infection, tuberculosis, mental illness or other illnesses if the employee voluntarily requests that his or her name be withheld. You do need to keep a separate, confidential identity list for these cases. Regardless of the injury or illness, if you share your records with anyone not authorized by the rule to see them, you must remove employee names before doing so.

  • Workers and their representatives have a right to review the 300 log no later than the end of the next business day, complete with names, except for privacy cases. Workers, former workers or personal representatives must be able to get copies of Form 301 covering their own injuries or illnesses by the end of the next business day. Authorized representatives can have access to just the "information about the case" section of any or all 301 forms within seven calendar days. You must provide records within four business hours to authorized government representatives such as OSHA inspectors or National Institute for Occupational Safety and Health (NIOSH) investigators.

Other Issues

  • There are some additional considerations. For temporary workers and contract workers, for example, you should record their injuries and illnesses the same as any other worker on your payroll, if you are supervising their work.

  • To be sure your records are complete, you must tell each employee how to report a work-related injury or illness. This means setting up a reporting system and informing each worker of the system.

No doubt there will be many questions as we make the transition to the new system. Issues probably will arise that need a further look. But the new system is a major improvement over the old for everyone. Improved records will help us better track injuries and illnesses and identify hazards that need further attention. Both workers and employers will benefit.

Connecticut Safety Society Symposium Update

The Connecticut Safety Society will be holding is annual symposium on Monday, November 12, 2001 at Foxwoods Resort and Casino. Featured guests and topics include:

  • State Senator Edith G. Prague

  • The New OSHA 300 Recordkeeping Regulations

  • Indoor Air Quality

  • Young Worker Safety

  • Workplace Violence

This symposium will also showcase a number of vendors, manufacturers, suppliers, and distributors of safety and health products.

For more information, contact Tom Hozebin, President, at (860) 566-4550.

OSHA 300 Log Training Sessions

If you would like more information regarding the new OSHA 300 Log, CONN-OSHA will be holding two training sessions that will include information to help employers comply with the new OSHA 300 requirements.

The session dates are:

  • Thursday, November 29, 2001, 9 am - 12 noon

  • Thursday, December 13, 2001, 9 am - 12 noon

The sessions are free of charge and open to public and private employers, but each session is limited to the first 40 registrants. They will take place at the CT Labor Department, 200 Folly Brook Boulevard, Wethersfield, CT. To register, please call Lisa Costanzo at (860) 566-4550.

OSHA-Quarterly Index

Last Updated: March 01, 2017

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