OSHA Recordkeeping Rule

OSHA recordkeeping

OSHA requires certain printing operations to record work related injuries and illness as well as report the summary of those electronically by March 2 of each year. OSHA’s recordkeeping regulation, at 29 CFR part 1904, requires employers who, at any time throughout the year, had more than 10 full, part time, or temporary employees track “recordable” occupational injuries and illnesses at their establishments. An injury or illness only qualifies as recordable if it required a response beyond what is considered first-aid. A list of first-aid considerations can be found here.

Required Forms

To start, ensure you have and understand the necessary forms for your facility. OSHA Injury and Illness Recordkeeping forms include:

  • Form 300 - the Injury and Illness Log
    Form 300 is to be kept current through the year. An employer has 7 calendar days after the event or being informed about an illness to record it in the form.
  • Form 301- the Incident Report
    Form 301 is also required to be completed within 7 calendar days after the event or being informed about an illness. These forms should be kept for a minimum of 5 years.
  • Form 300A - the Summary of Work-Related Injuries and Illnesses
    At the end of each calendar year, all entries from Form 300 are to be totaled and recorded on Form 300A. This form should not include any personal information that may have been included on Form 300.

Find links to all three forms in fillable PDF form as well as instructions on completion here.

Posting Form 300A

OSHA Form300A

Once Form 300A is completed, it must be:

  1. “Certified” with a signature of a responsible company official
  2. Posted in a visible public place within the facility no later than February 1
  3. Kept up until April 30

Electronic Submission

As of 2017, 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 by March 2, their Form 300A data, not the actual Form 300A for the previous year. The application is accessible at the Injury Tracking Application webpage.

The data submission process involves four steps:

  1. Creating an establishment
  2. Adding 300A summary data
  3. Submitting data to OSHA
  4. Reviewing the confirmation email

The secure website offers three options for data submission. One option will enable users to manually enter data into a web form. Another option will give users the ability to upload a CSV file to process single or multiple establishments at the same time. A third option will allow users of automated recordkeeping systems to transmit data electronically via an application programming interface (API.)

In order to demonstrate that you have met the new reporting requirement, you should keep copies of all the electronic correspondence from OSHA.

PRINTING United Alliance Resources

PRINTING United Alliance has developed an OSHA Recordkeeping Checklist to help member facilities comply with OSHA’s injury and illness recordkeeping rule. While additional and more detailed information may be necessary with individual cases, this checklist is designed to provide the foundation for recording, maintaining and reporting the correct information.

Use PRINTING United Alliance's checklist to ensure that your records and documentation are up to date!

PRINTING United Alliance’s OSHA Compliance Resource Center provides technical assistance and services designed to allow printing operations to manage compliance and stay informed. For more information on OSHA Recordkeeping or PRINTING United Alliance’s EHS services, email govtaffairs@printing.org or call 888-385-3588.