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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].

General Guidance
Question 1. Why is OSHA changing the 1904 regulation?

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)
Question 3. 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 4. 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 5. 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.

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