OSHA Proposes Improved Records for Workplace Injuries

The U.S Occupational Safety and Health Administration (OSHA) requires workplaces to submit annual data related to employee injuries. However, a recent OSHA proposal could lead to changes in the process. 

What Does the Current Process Require?

When someone gets injured or sick on the job, the relevant parties at the workplace must input data on: 

• Form 300
• Form 300A
• Form 301

What’s the Difference Between These Forms?

Form 300 is a log that identifies and describes the injury, including the date it occurred and the person’s job title. People must additionally classify the incident and its consequences by selecting applicable checkboxes. OSHA does not require organizations to submit Form 300, but data from that report gets used to fill out Form 300A, which does go to OSHA. 

Form 300A is a summary report of all Form 300 data. It covers details like the total number of deaths and recordable incidents, including the number of days away from work or the number of times those issues required a person to transfer to a new role or restrict what they performed in their usual position.

OSHA considers recordable incidents in a broader way than some people may expect. This category does cover incidents that happen directly on the job. However, it also extends to cancer diagnoses and fatalities related to work. In such cases, something a person did on the job caused the development or exacerbation of the issue or an incident occurring at work triggered or worsened the problem. 

Form 300A does not have employee names. It acts as a tally for all workplace incidents in a given timeframe. 

Then, Form 301 is paperwork that people should complete at the same time as adding content to Form 300. It allows giving more in-depth information about what happened in a particular incident and how it affected the worker involved. 

As of now, workplaces that have 250 or more employees and are not in high-hazard industries must submit Form 301 to OSHA each year. Additionally, workplaces in high-hazard industries that have 20-99 employees must do the same. 

What Does the OSHA Proposal Suggest?

OSHA may update its recordkeeping rules for employee injuries. The new proposal would require workplaces with 100 or more employees operating in certain high-hazard industries to electronically submit information from Forms 300, 300A and 301 each year. So, the main changes in that case relate to sending the data  from the two additional forms. 

The existing submission requirements for companies in high-hazard industries with 20-99 employees would remain unchanged. However, the OSHA proposal would remove the reporting requirement for organizations with 250 or more employees not operating in high-hazard industries. 

Another proposed change by OSHA would require submitting the company name with the documentation. Additionally, OSHA proposes updating the classification system that currently dictates which industries fall under the high-hazard umbrella for electronic data submissions. 

How Could This Proposal Help Improve Workplace Safety?

OSHA anticipates numerous benefits stemming from the proposal if enacted. It would allow the organization to better identify the workplaces where employees are at an elevated risk of specific hazards. It could then use that information to improve its compliance and enforcement measures. 

Since the OSHA proposal would require workplaces to send the data from two additional forms, the change could result in improved incident tracking. More specifically, it could help a workplace compare how its injury and illness rates stack up to similar organizations in the same industry. 

The OSHA proposal should also improve research on associated safety trends. Data indicates there were 5,333 U.S workplace fatalities during 2019. If OSHA has more data about deaths and serious injuries or illnesses, it could change future policies to keep people safer.

For example, that data could get distributed to regional, state and local bodies tasked with overseeing workplace safety in their respective domains. Moreover, since the proposed changes would require submitting workplace names with the data, it could be easier to determine which organizations may need extra oversight due to worrying injury or illness patterns. 

What Happens Next?

People have until May 31, 2022,  to submit comments about this proposal. From there, OSHA representatives will take them into account, using that information to help determine whether the proposal’s changes will become mandated. 

Organizational representatives who may be affected by the changes should strongly consider assessing their workflows and processes now to determine how they could most effectively adapt to the changes if they come to pass. 

They should also stay abreast of OSHA’s proposed changes regarding the classification system that covers whether an organization within a given industry must submit these electronic records. Then, it’ll be easier to get prepared for any changes if they’re necessary. 

Finally, organizations with 250 or more employees not in high-hazard industries should not prematurely assume they no longer need to submit Form 301 each year. If OSHA’s proposal gets enacted, those submissions can cease. However, it will take some time for that to happen, if it does.

The best thing for applicable organizations to do now is to understand what’s changing and how it may affect them. Then, if it becomes necessary to do things differently relatively soon, such process transitions should be more streamlined.