OSHA Final Rule Changes Injury Recording and Reporting Requirements Effective January 1, 2015

On September 11, 2014, the Occupational Safety and Health Administration (OSHA) announced changes to the list of industries that are exempt from the requirement to routinely keep OSHA injury and illness records, and to the list of severe work-related injuries and illnesses that all covered employers must report to OSHA.  The final rule goes into effect January 1, 2015.

Recordkeeping Requirements

The final rule introduces a new classification system to determine which employers with 11 or more employees must maintain injury and illness records.  Industries will now be classified using the North American Industry Classification System (NAICS) instead of the Standard Industrial Classification (SIC) system. Businesses can find their NAICS code on the U.S. Census Bureau NAICS webpage here.

Under the new classification system, some employers will no longer be required to keep records while others now will now be required to keep records.  Among the industries that must start keeping records are automotive dealers, bakeries, building material and supplies dealers, specialty food stores, liquor stores, consumer goods rental, and event promoters.

Employers required to keep records of occupational injuries and illnesses at their establishments must keep the following:

  • OSHA Form 300 – Log of Work-Related Injuries and Illnesses
  • OSHA Form 301 – Injury and Illness Incident Report
  • OSHA Form 300A – Summary of Work-Related Injuries and Illnesses

OSHA Forms 300 and 301 must be completed within seven calendar days of the time a recordable fatality, injury or illness occurred. OSHA Form 300A must be posted in the workplace from February 1 through April 30, even if no recordable work-related injuries or illnesses occurred during the year.

Reporting of Work-Related Injuries

OSHA’s updated recordkeeping rule expands the list of severe injuries that employers must report to OSHA. As of January 1, 2015, all employers must report:

  1. All work-related fatalities within 8 hours.
  2. All work-related inpatient hospitalizations, all amputations and all losses of an eye within 24 hours.

Employers may report to OSHA by:

  1. Calling OSHA’s free and confidential number at 1-800-321-OSHA (6742).
  2. Calling the closest Area Office during normal business hours.
  3. Using a new online form coming soon to OSHA’s website at www.osha.gov.

OSHA hopes to improve workplace health and safety by also proposing a rule that would require employers to submit electronically their illness and injury reports and making the information available on the OSHA website. More information and tools to help employers comply with the January 1 recordkeeping requirements is available here.