Updated: OSHA Recordkeeping – New Rules You Need to Know

[fa icon="calendar'] Sep 28, 2016 10:09:16 AM / by Deborah Lechner

MAY 2017 UPDATE: OSHA has suspended the e-recordkeeping rule. Read more about this change from OSHA.

In May 2016, the Occupational Safety and Health Administration (OSHA) passed down a final rule to revise workplace injury recordkeeping practices in an effort to improve safety for U.S. workers.

The new rule should create many efficiencies for OSHA, specifically because it requires employers of certain industries to electronically submit OSHA injury and illness data. Current OSHA regulations already require these forms be filled out at the employer’s site. This new rule allows OSHA to be able to analyze submissions a lot more quickly and to identify those employers who are not in compliance or have high injury rates. Perhaps the most visible and immediate impact of this rule change is that OSHA will begin posting some of the injury and illness data received from employers to their website, replacing the previous manual reports employers were required to submit. While this will certainly provide increased transparency to employees, applicants and the general public about workplace injuries, many companies - especially larger corporations – are very concerned about their image in the communities where they do business. Why? Because declining workforce participation rates and a rapidly aging labor pool make it harder and harder to recruit qualified applicants. If potential applicants can go to a website and see that the company has been cited by OSHA for safety violations or if they have high rates of injury, they may not apply at all.

Dr. David Michaels, assistant secretary of Labor for OSHA, says, “Our new rule will 'nudge' employers to prevent work injuries to show investors, job seekers, customers and the public they operate safe and well-managed facilities. Access to injury data will also help OSHA better target compliance assistance and enforcement resources, and enable 'big data' researchers to apply their skills to making workplaces safer."

The new rule, requiring electronic submission of data, goes into effect January 1, 2017. Regardless of the format – paper or electronic – employers should strive to complete all required forms with adequate detail, especially OSHA’s 301 form, the Injury and Illness Incident Report. This form is important because it collects all of the details around a specific incident — it asks questions concerning what the employee was doing before the injury, what happened, what was injured, what body part, etc. OSHA’s 300 and 300A forms collect similar information, as well.

The information collected on these OSHA forms provides granular data that is extremely useful when companies want to know what they can do to prevent injuries. Without knowing what is causing the injuries, where and when they are happening, the tenure and age of the injured employees, it is hard to figure out what to do about them. When it comes to data, more is nearly always better.  Armed with the details, safety professionals can use company-specific data analysis to create and maintain effective injury and illness prevention programs.

But even more important than recording injuries in detail is preventing them from happening in the first place. The implementation of injury prevention strategies, such as pre-hire physical abilities testing, ergonomic risk assessment, implementation of ergonomic controls and employee training can help employers prevent injuries and avoid OSHA penalties and fines (and avoid filling out OSHA forms in the first place).

OSHA also says of the new rule that “the more attention to safety will save the lives and limbs of many workers and will ultimately help the employer’s bottom line.” And that’s not just talk: there are numerous studies that support the idea that paying attention to safety pays in lots of other ways, too.

A 2009 study by Huang et al., published in Professional Safety, surveyed 231 financial executives at medium to large companies with 100 employees or more about their views on safety. When the participants were asked about what they perceived to be the top benefit of effective workplace injury prevention programs, 42.5 percent said it was increased productivity, while 28.3 percent reported reduced costs, 7.1 percent felt it led to greater employee retention and 5.8 percent saw better morale and greater job satisfaction. 


The greater focus on injury prevention resulting from this rule change will be recognized and appreciated by employees, as well. Employers will be required to let employees know of their right to report work-related injuries and illnesses without fear of retaliation. When employees feel appreciated and cared for, morale and productivity increase. 

The bottom line is that careful documentation and injury prevention pay off. Companies aiming to reduce their injuries should start by making sure their recordkeeping is thorough and detailed so the information collected can be used to mitigate future injuries. And even more importantly, organizations can seek advice from workplace injury prevention experts. Such expert advice can help employers interpret their data and develop strategies to prevent future injuries – which in turn helps them reduce expenses, eliminate lost productivity, and avoid a tarnished reputation and the red tape of OSHA reporting.

Is a pre-hire screening program cost-effective? Find out in this independent study.

Topics: Workplace Safety, OSHA Requirements, Physical Abilities Tests

Deborah Lechner

Written by Deborah Lechner

Deborah Lechner, ErgoScience President, combines an extensive research background with 25-plus years of clinical experience. Under her leadership, ErgoScience continues to use the science of work to improve workplace safety, productivity and profitability.