Frequently Asked Questions for
OSHA's Injury and Illness Recordkeeping Rule
OSHA's Injury and Illness Recordkeeping Rule
This document provides general guidance about OSHA's revised recordkeeping rule and provides links to more detailed guidance. The questions and answers in the Additional guidance portion of this document do not themselves impose enforceable recordkeeping or reporting obligations; such obligations are imposed only by the regulation. This version was last updated on [11/21/01].
Question 1. Why is OSHA changing the 1904 regulation?Detailed Guidance
OSHA is revising the rule to collect better information about the incidence of occupational injuries and illnesses, improve employee awareness and involvement in the recording and reporting of job-related injuries and illnesses, simplify the injury and illness recordkeeping system for employers, and permit increased use of computers and telecommunications technology.
Question 2. What recordkeeping actions will take place on January 1, 2002?
A number of actions will take place on January 1, 2002, including:
The revised 29 CFR Part 1904, entitled Recording and Reporting Occupational Injuries and Illnesses, will be in effect.
Three new recordkeeping forms will come into use:
- OSHA Form 300, Log of Work-Related Injuries and Illnesses
- OSHA Form 300A, Summary of Work-Related Injuries and Illnesses
(The 300 and 300A forms will replace the former OSHA Form 200, Log and Summary of Occupational Injuries and Illnesses)
- OSHA Form 301, Injury and Illness Incident Report
(The 301 form will replace the former OSHA Form 101, Supplementary Record of Occupational Injuries and Illnesses)
The Bureau of Labor Statistics (BLS)/OSHA publications: Recordkeeping Guidelines for Occupational Injuries and Illnesses, 1986 and A Brief Guide to Recordkeeping Requirements for Occupational Injuries and Illnesses, 1986 will be withdrawn.
All letters of interpretation regarding the former rule's injury and illness recordkeeping requirements will be withdrawn and removed from the OSHA CD-ROM and put into the OSHA Archive Set.
Question 3. How can I get copies of the new forms?
Copies of the forms can be obtained on OSHA's web site at http://www.osha.gov or from the OSHA publications office at (202) 693-1888.
Question 4. Can I start using a 300 Log prior to January 1, 2002?
No. You must continue to keep a 200 Log for the remainder of 2001. Employers may not start using a 300 Log until January 1, 2002, because this is the effective date of the new regulation.
Question 5. Can I compare injury and illness rates generated from my OSHA form 300, and the new regulation, to injury and illness rates generated from my OSHA 200 Log under the old rule (i.e., compare 2001 data with 2002 data)?
The new recordkeeping rule changes some of the criteria used to determine which injuries and illnesses will be entered into the records and how they will be entered. Therefore, employers should use reasonable caution when comparing data produced under the old 1904 regulation with data produced under the new rule.
Question 6. Are the recordkeeping requirements the same in all of the States?
The States operating OSHA-approved State Plans must adopt occupational injury and illness recording and reporting requirements that are substantially identical to the requirements in Part 1904 and which should also be in effect on January 1, 2002. For more information, see the discussion under "States Requirements," §1904.37.
Most of the questions that OSHA has received about the detailed provisions of the new rule are answered in the regulation itself. However, other questions arise that are not directly answered, and OSHA has developed additional guidance to help employers comply with the recordkeeping requirements. The following table of contents provides links to additional guidance, or, if additional guidance has not been developed, to the regulation.
1904.1 Partial exemption for employers with 10 or fewer employees.
1904.2 Partial exemption for establishments in certain industries.
1904.3 Keeping records for more than one agency.
1904.4 Recording criteria.
1904.5 Determination of work-relatedness.
1904.6 Determination of new cases.
1904.7 General recording criteria.
1904.8 Recording criteria for needlestick and sharps injuries.
1904.9 Recording criteria for cases involving medical removal under OSHA standards.
1904.10 Recording criteria for cases involving occupational hearing loss.
1904.11 Recording criteria for work-related tuberculosis cases.
1904.12 Recording criteria for cases involving work-related musculoskeletal disorders.
1904.30 Multiple business establishments.
1904.31 Covered employees.
1904.32 Annual summary.
1904.33 Retention and updating.
1904.34 Change in business ownership.
1904.35 Employee involvement.
1904.36 Prohibition against discrimination.
1904.37 State recordkeeping regulations.
1904.38 Variances from the recordkeeping rule.
1904.39 Reporting fatalities and multiple hospitalization incidents to OSHA.
1904.40 Providing records to government representatives.
1904.41 Annual OSHA Injury and Illness Survey of Ten or More Employers.
1904.42 Requests from the Bureau of Labor Statistics for data.
1904.43 Summary and posting of year 2000 data.
1904.44 Retention and updating of old forms.
1904.45 OMB control numbers under the Paperwork Reduction Act