OSHA Safety & Risk Management Update | Recordkeeping Requirements

OSHA has delivered their final rule on the recordkeeping requirements.

The new law goes into effect January 1, 2017 and has a three year phase in plan.

These dates are July 1, 2017 (only 300A summation information), July 1, 2018 (partial requirement for all forms for large companies), and March 2, 2019 (full implementation).  For the companies that must submit the additional information from the 300 log and 301 forms, understand that there is no personal information or other employee related references.

What are the Requirements:

  • All companies with greater than 250 employees (not on the recordkeeping exemption list – https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html) will have to submit information from the 300 log, 300A summation, and some information from the 301 (Incident Report) on an annual basis via an electronic submission website for OSHA.
  • Companies with 20-249 employees (not on the recordkeeping exemption list) will only have to submit the information from the 300A summation log
  • Companies with less than 20 employees will only have to submit information if OSHA instructs them to do so.

In general, all companies should be completing this information collection already (unless on the exclusion list) and posting it in their location from February 1st to April 30th of every calendar year. The electronic submission requirement will take the place of the annual survey that was sent to select companies.

Starting January 1, 2017, all companies will have to comply with the recordkeeping submission. This new rule does not alter any previous recordkeeping requirements as stated by OSHA 1904 and will still require 300 logs be filled out within 7 days of an injury, 301’s (or site specific incident reports) immediately following an injury, and 300A logs completed for the previous calendar year and posted.

The new standard also give OSHA additional enforcement powers against those companies who retaliate against employees who report an injury and also for those companies whose incentive programs strongly lead to the hiding of injuries.

Read an article from EHS Today regarding the new federal requirements for injury data collection and its hope to nudge employers to prevent workplace injuries and illnesses.


Questions? Contact Lara Ward, Loss Control Advisor | 216.777.6116