Recording and Reporting

Compliance dates:

Dec. 31, 2017 - Electronic submission of OSHA 300A (Annual Summary) data for calendar year 2016.

Federal OSHA has indicated that employers that did not submit required 2016 data by Dec. 31, 2017 can still do so by sending hard copies for OSHA to manually enter this information into their database. In North Carolina, employers that need to submit their 2016 data can either send an email with attachments to the attention of Karen Bogner of the OSH Planning, Statistics and Information Management (PSIM) Bureau at karen.bogner@labor.nc.gov or via mail at:

Ms. Karen Bogner
North Carolina Department of Labor
OSH Division / PSIM Bureau
1101 Mail Service Center
Raleigh, NC 27699-1101

 

Feb. 1, 2018 - OSHA 300A for calendar year 2017 must be posted in the work establishment from Feb. 1, 2018 through Apr. 30, 2018.

July 1, 2018 - The date by which certain employers are required to electronically submit the information from their completed 2017 Forms 300, 300A and 301 to OSHA. Details about this requirement can be found on the OSHA website.

Injury and Illness Recordkeeping

OSHA Injury Tracking Application

OSHA Injury Tracking Application

What is the Injury Tracking Application (ITA)?

This is Federal OSHA's new requirement that requires two classes of employers to submit injury and illness data electronically using a secure website.

Who is required to submit their information to the ITA?

  • Employers in certain high hazard industries must submit injury and illness data from their OSHA Form 300A (Annual Summary) for establishments having between 20 and 249 employees at any time during the calendar year.

  • Employers who are already required to maintain injury and illness records must submit injury and illness data from their OSHA Forms 300, 301 (or NC Industrial Commission's Workers Compensation Form 19), and 300A for establishments that have 250 or more employees at any time during the calendar year.

Is the requirement based on employer size?

No, the requirement to comply with these new electronic recordkeeping requirements is based on the number of employees at each establishment.

How can employers access the ITA?

The ITA can be accessed on the OSHA website.

What is the deadline for entering this information into the ITA?

Certain employers are required to electronically submit the information from their completed 2017 Form 300A to OSHA by July 1, 2018. The deadlines for submitting injury and illness data for future calendar years, as well as additional information about this requirement, can be found on the OSHA website.

Overview

Overview

What is meant by recording or recordkeeping?

In the context of this discussion, "recording" or "recordkeeping" refers to the entry of information on the OSHA injury and illness log (OSHA Forms 300 and 301) by employers about work-related incidents that results in one or more of the following outcomes to an employee: death; loss of consciousness; days away from work or restricted duty; transfer to another job; and medical treatment beyond first aid. In addition, a work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums must be also be recorded.

In North Carolina, employers may use the Workers Compensation Form 19 as an equivalent form for the OSHA Form 301.

What is meant by reporting?

"Reporting" refers to the requirement for employers to report to OSH any work-related fatality, in-patient hospitalization, amputation or loss of an eye within specified periods of time.

  • In-patient hospitalization is a formal admission to the in-patient service of a hospital or clinic for care or treatment.
  • An amputation is the traumatic loss of a limb or other external body part. Amputations include a part, such as a limb or appendage, that has been severed, cut off, amputated (either completely or partially); fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; amputations of body parts that have since been reattached. Amputations do not include avulsions (tissue torn away from the body), enucleations (removal of the eyeball), deglovings (skin torn away from the underlying tissue), scalpings (removal of the scalp), severed ears, or broken or chipped teeth.
  • Loss of an eye is the physical removal of the eye. This includes enucleation and evisceration.

What is considered medical treatment?

The definition of "medical treatment" means the management and care of a patient to combat disease or disorder. For the purposes of the recordkeeping standard, medical treatment does not include:

  • Visits to a physician or other licensed health care professional solely for observation or counseling;
  • The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils); or
  • "First aid" as defined below.

 What is considered first aid?

The definition of "first aid" means the following:

  • Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
  • Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment);
  • Cleaning, flushing or soaking wounds on the surface of the skin;
  • Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
  • Using hot or cold therapy;
  • Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
  • Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.).
  • Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
  • Using eye patches;
  • Removing foreign bodies from the eye using only irrigation or a cotton swab;
  • Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
  • Using finger guards;
  • Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
  • Drinking fluids for relief of heat stress.
Regulations

Regulations

Which Standards Apply?

29 CFR Part 1904, featuring but not limited to:

  • 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

  • 1904.10 - Recording criteria for occupational hearing loss

  • 1904.30 - Multiple business establishments

  • 1904.32 - Annual summary

  • 1904.39 - Reporting fatalities, hospitalizations, amputations, and loss of an eye

  • 1904.41 - Electronic submission of injury and illness records to OSHA

OSH automatically adopts all recordkeeping standards for application in North Carolina when published in the Federal Register in accordance with 13 NCAC 07A. 0301(a).

How Do I Report an Accident?

How Do I Report an Accident?

Work-related fatality:

  • Report to the OSH Division within eight hours after the death of an employee as a result of a work-related incident.

During working hours (weekdays, 8 a.m. to 5 p.m.), call 1-800-625-2267 or 919-779-8560. After working hours (5 p.m. to 8 a.m.), weekends or holidays, call State Capitol Police at 919-733-3333.

Work-related injury involving one or more of the following:

  • Any in-patient hospitalization of one or more employees
  • Any work-related amputation
  • Any work-related loss of an eye

Report to the OSH Division within 24 hours of the incident. Call 1-800-625-2267 or 919-779-8560.  Any in-patient hospitalization of one or more employees, any work-related amputation, and any work-related loss of an eye may also be reported through the online accident reporting form.

For any incidents resulting in the hospitalization of two or more employees after working hours, weekends or holidays, call State Capitol Police at 919-733-3333.

What if the fatality, in-patient hospitalization, amputation, or loss of an eye does not occur during or right after the work-related incident?

If a fatality occurs within 30 days of the work-related incident, or if an in-patient hospitalization, amputation, or loss of an eye occurs within 24 hours of the work-related incident, then you must report the event. If the fatality occurs after more than 30 days of the work-related incident, or if the in-patient hospitalization, amputation, or loss of an eye occurs after more than 24 hours after the work-related incident, then you do not have to report the event. However, you must record the event on your OSHA injury and illness records, if you are required to keep OSHA injury and illness records.

Learn More

Learn More

Where can I learn more?

If you would like to receive interpretive guidance on this or any other OSH standard or topic, you can submit your questions using the Ask OSH web form, by e-mail to ask.osh@labor.nc.gov or by calling 919-807-2875.