OSHA's Injury and Illness Recordkeeping and Reporting Requirement Reminders
As we move into the new year, there are two important mandatory OSHA record-keeping requirements that printing operations need to be aware of and, most importantly, comply with if they meet the thresholds. The requirements involve the completion, posting, and submission of certain forms that are separate, but related.
Throughout the calendar year, OSHA requires establishments with more than 10 full-, part-time, or temporary employees to complete and maintain a Form 300 Log of Work-Related Injuries and Illnesses. This is to be completed for each work-related, recordable injury and illness or fatality occurring in the workplace. The form has three general sections that include information on the identification of the person (e.g. employee name, case number, job title), description of the incident (e.g. date, injury location, description of incident), and classification (e.g. type of injury, days away from work, days on restriction).
OSHA has a definition of what constitutes a work-related injury and illnesses, and it is essentially any incident that is beyond what is considered first aid. There is a specific list of first aid activities, and if the response to an incident does not appear on this list then it is considered recordable and must be entered into Form 300.
The Form 300 is to be kept current through the year, and the employer has seven calendar days after the event or being informed about an illness to record it. At the end of each calendar year, all entries are to be totaled, and the summary of the information recorded onto Form 300A, Summary of Work-Related Injuries & Illnesses. OSHA Form A is a separate form, and does not display any of the personal information.
The Form 300A is a summation from columns G through M of the OSHA Form 300 during the previous calendar year. The form also has the calendar year covered, company name and address, annual average number of employees, and total hours worked by all employees covered by the OSHA Form 300 log. OSHA Form 300A also makes it easier to calculate incident rates
Once the Form 300A is completed, it must be “certified” with the signature of a responsible company official and posted no later than February 1, and kept in place until April 30. It must be posted in a conspicuous place or places where notices to employees are customarily posted.
The person who certifies a 300A can be any of the following:
- owner of the company (only if the company is a sole proprietorship or partnership)
- officer of the corporation
- the highest ranking company official working at the establishment
- the immediate supervisor of the highest ranking company official working at the establishment
Filing Forms Electronically
Beginning in 2017, OSHA instituted a new electronic injury and illness reporting requirement. While there was some confusion regarding the deadline for submission due to the requirements being phased in, the deadline is now set for March 2. This requirement is related to the Form 300A, but the threshold for reporting is different than having to maintain a Form 300. OSHA requires any printing establishment that has, or had at any time last year, more than 20 full time, part time, or temporary employees to electronically submit their Form 300A data, not the actual Form 300A.
In order to accept the data, OSHA created the Injury Tracking Application (ITA). The Web-based form allows employers to electronically submit required injury and illness data from their completed 2019 OSHA Form 300A. The application is accessible at the ITA webpage (https://www.osha.gov/injuryreporting/index.html).
The data submission process involves four steps:
- Creating an establishment
- Adding 300A summary data
- Submitting data to OSHA
- Reviewing the confirmation email
The secure website offers three options for data submission. One enables users to manually enter data into a web form. Another gives users the ability to upload a CSV file to process single or multiple establishments at the same time. And the third allows users of automated recordkeeping systems to transmit data electronically via an application programming interface (API.)
A new requirement for the 2020 reporting year is the need to provide your Employer Identification Number (EIN). This change was implemented to allow OSHA to better identify establishments as the names of companies can change over time.
In order to demonstrate that you have met the new reporting requirement, you should keep copies of the electronic correspondence from OSHA.
Resources to Help Make Sense of the Requirements
OSHA’s regulations can be confusing as they apply to establishments, and not companies. In many instances, it is one in the same if a printing operation has only one place of business. An establishment is defined as a single physical location where business is conducted, or where services or industrial operations are performed. A firm may be comprised of one or more establishments. To determine if you need to provide OSHA with the required data for an establishment, you need to determine the establishment's peak employment during the last calendar year. Each individual employed in the establishment at any time during the calendar year counts as one employee, including full-time, part-time, seasonal, and temporary workers.
Maintaining and posting OSHA’s forms, and submitting injury and illness data electronically are mandatory requirements. Even if a printing operation did not have any recordable injuries, they are still required to complete Form 300, post Form 300A, and submit their data to OSHA. It is also important to keep in mind that the thresholds for these two requirement are separate from injury reporting, which has no thresholds and every printing operation is required to report within 8 hours any fatality, and within 24 hours any amputation, injury involving hospitalization requiring treatment, or loss of an eye. Failure to maintain the forms, submit the injury and illness data, or to report an injury subjects the company to citations and penalties.
The SGIA Government Affairs Department has many resources, such as written program templates, designed to assist printing operations address their compliance programs. Please contact the Government Affairs Department at email@example.com for assistance.
Gary Jones is the director of environmental, health and safety (EHS) affairs at the Specialty Graphic and Imaging Association in Fairfax, VA. His primary responsibility is to monitor and analyze EHS regulatory activities at all domestic and some international government levels. He provides representation on behalf of the printing and specialty graphic imaging industry. In doing so, Jones works closely with the federal and state-level Environmental Protection Agencies (EPA), Occupational Safety and Health Agency (OSHA), Department of Transportation (DOT), and other agencies. He also provides membership assistance on EHS compliance and sustainability programs through a variety of approaches including responding to inquiries, presentations, writing, and consulting services.