This time of year, as Occupational Safety and Health Administration (OSHA) reporting deadlines are upon us, we tend to be very focused on workplace safety incident reporting. But the fact is, that reporting and investigating safety incidents at the workplace should be a year-round focus.
While investigation and documentation are certainly relevant for any number of reasons—identifying safety concerns, etc.—properly filling out the OSHA reporting forms can sometimes be time consuming and confusing. And as we head into 2023, OSHA has promised some significant record-keeping changes, so keeping your records in order throughout the year is all the more important.
This is critical for all workplaces, but even more so for industries like construction and manufacturing with inherent safety risks. Worker injuries are statistical math. Incidents can and do happen, and when they occur, OSHA has a whole other set of rules and regulations for how injuries or illnesses should be investigated, documented and reported.
The following five tips can help make the reporting process easier for you and your employees.
Tip No. 1: Develop a standard incident reporting procedure with investigation
OSHA requires you to establish a reasonable procedure for employees to report work-related injuries and illnesses to you (the employer). You are then required to share this information with employees, and OSHA can cite you for discouraging workers from reporting injuries.
While you are not required to report all incidents, injuries or illnesses to OSHA (see Tip No. 2), OSHA strongly encourages employers to investigate all safety incidents (even those without injury) as part of a comprehensive safety program.
Including investigation in your first response to incidents will make it much easier to accurately complete the questions about recordable cases on the OSHA Incident Report (Form 301) if it is required. A supervisor or manager trained as a first-response investigator can quickly:
- Arrange for first aid or medical treatment of the injured worker(s).
- Secure and document the scene.
- Interview the injured worker and identify and interview witnesses.
- Collect information relevant to the case (questions on Form 301).
- What was the employee doing just before the incident occurred?
- What happened? What was the specific injury or illness?
- What object or substance directly harmed the employee?
There are helpful tools available to help streamline record-keeping. McClone is the exclusive provider of OSHAlogs in Wisconsin. OSHAlogs.com is a secure, web-based application that lets you easily file your state’s first report of injury, print required OSHA reports, track injuries and view injury metrics in real-time.
Tip No. 2: Train employees to understand criteria for OSHA recordable
There is a difference between incidents you want your employees to report to you for safety training purposes and the “recordable” incidents you need to report to OSHA.
This can be confusing for employees and supervisors alike, sometimes resulting in over-reporting as well as under-reporting. You don’t want employees to fail to report a potential safety issue, but you also don’t want an inflated incident report to impact your insurance costs or trigger unwarranted OSHA inspections.
Some employers have found it helpful to create and post emergency and non-emergency incident reporting criteria in the workplace for employees to reference as follow-up to safety training. Supervisors responsible for recordkeeping are given a decision tree to determine if injuries or illnesses meet the criteria for OSHA recordable incidents. These visual aids provide a quick reference and can make reporting easier, faster and more accurate. 
Tip No. 3: Remember OSHA counts calendar days NOT working days
If you don’t regularly work weekends, it’s easy to get in the habit of counting a workweek as five days. In many industries, however, work is available seven days a week. So, OSHA uses calendar days when counting both reporting deadlines and number of days an injured worker is restricted or away from work.
Deadlines: OSHA requires you to record non-fatal incidents within seven calendar days of your notification of the injury (for example, if a worker doesn’t report an injury for two days, or an illness for two years, you still have seven days from the date you find out). You are required to immediately report fatalities, hospitalizations, amputations or the loss of an eye.
Days away from work: OSHA requires you to count calendar days, including scheduled vacation days, weekends and holidays. You do not count the day the injury or illness began. For example, you have an employee who is scheduled to work Monday through Friday. He is injured on Friday but reports back to work on Monday. Even though he is not scheduled to work Saturday and Sunday, those days still must be counted as days away from work. So, this injury is counted as two days away from work unless a healthcare provider says he would have been fit to work over the weekend.
Tip No. 4: Brag a little—zero incidents still need to be posted on OSHA Summary
All covered employers are required to maintain OSHA records and post the OSHA 300A Summary of Work-Related Injuries and Illnesses in a conspicuous area of the workplace (many employers post it with other required employment posters). If you are subject to electronic reporting, you must also submit your OSHA Form 300A by March 2 every year.
If you had zero incidents to record for the year, you are still required to post the summary with zeros in the fields that require total numbers.
Tip No. 5: Think of different locations as separate reporting establishments
If you have multiple locations, you will need separate OSHA records, log and summary for each location that documents the injuries and illnesses at that specific establishment (a single physical location where business is conducted or where services or industrial operations are performed). OSHA does not permit you to have one master (combined) set of OSHA records for all business locations.
If you have employees who work remotely and/or never report to a fixed location, you must assign these employees to an establishment for OSHA recordkeeping purposes.
Looking to streamline your OSHA recordkeeping?
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