| 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?
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,
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