OSHA Record-keeping Requirements

This document explains how to complete OSHA Forms 300, 300-A, and 301 and when to keep a separate confidential list for “privacy concern” cases. It was written by John Loomos, Esq. formerly of ALPA and Eastern Air Lines. A 2018 Department of Labor Trade Release informed employers they must electronically submit information from Form 300, 300-A, and 301 to OSHA. Form 300-A, the Summary, must be posted no later than February 1 each year even if there are no injuries (it must be posted with zeros in the total lines) and provided to employees. The Government representatives authorized to receive records are listed. Any OSHA Survey or Bureau of Labor Statistics Survey must be promptly completed and returned.

OSHA Record-keeping Forms

The following document explaining how to fill out OSHA’s required record-keeping forms — 

  1. Form 300, the Log of Work-Related Injuries and Illnesses; 
  2. Form 300-A, the Summary of Work-Related Injuries and Illnesses reported on Form 300; and 
  3. Form 301, the Injury and Illness Incident Report, 

— was written by John Loomos, Esq., in 2002.  

April 30, 2018, DOL Trade Release

According to a U.S. Department of Labor Trade Release dated April 30, 2018, notice was given that OSHA had taken action to correct an error made with regard to implementation of the final rule.  

OSHA determined that Section 18 (c) (7) of the Occupational Safety and Health Act and relevant OSHA regulations pertaining to State Plans, require all affected employers to submit injury and illness data in the Injury Tracking Application (ITA) Online Portal even if the employer is covered by a State Plan that has not completed adoption of their own state rule.  Employers must electronically submit information from the Form 300, Form 300A, and Form 301 to OSHA by July 1, 2018.  

The records kept on paper (prior to the 2018 requirement to submit electronically) must be kept for five years.

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