OSHA 300 & 300A forms and incident rates: What do they represent to an employer?

| OSHA, USF Safety Florida

Written by: Pat Stark, CHST, PCC, PCG, Senior Safety and Health Consultant, USF SafetyFlorida

Most employers need to maintain the OSHA 300 and 300A at their establishment. OSHA defines an establishment as a single physical location where business is conducted or where services or industrial operations are performed. Many employers in the U.S. are also required to electronically log onto the OSHA website to OSHA’s Injury Tracking System and submit their 300A data for the most recent full calendar year.

Businesses required to submit to the OSHA Injury Tracking System include establishments with 250 or more employees currently required to keep OSHA injury and illness records, and establishments with 20-249 employees operating in industries outlined in OSHA’s Final Rule. It is important to note, businesses operating in the industries outlined in OSHA’s Final Rule are required to submit their OSHA 300A information in the OSHA Injury Tracking System.

For more information on reporting illnesses and injuries visit  https://www.osha.gov/injuryreporting/.

Incident rates

The incident rates of the 2018 Bureau of Labor Statistics (BLS)—which are the most current since these rates remain about two years behind the actual calendar year—reflect in a table the Incidence rates of nonfatal occupational injuries and illnesses by industry and case types. The industry type is reflected in the North American Industrial Classification System (NAICS). Total case rate (TRC) is represented by total number of OSHA 300 injuries and illnesses per 100 full-time workers and were calculated as: (N/EH) x 200,000, where N = number of injuries and illnesses EH = total hours worked by all employees during the calendar year 200,000 = base for 100 equivalent full-time workers (working 40 hours per week, 50 weeks per year). The days-away-restricted-transfer (DART) include those OSHA 300 cases that result in days away from work with or without job transfer or restriction.

For instance, the table 1 of the 2018 BLS 2018 Masonry contractors (NAICS of 23814) shows a TRC of 4.0 and a DART of 1.7. A masonry contractor can review this 2018 table and see if their incident rates are higher or lower than the national rates. An employer should always strive for their incident rates to be lower than the latest BLS incident rate and track these rates on a yearly basis to see if their trend is going up or going down. Of course, the particular BLS industry incident rate will usually change slightly up or down from year to year as well.

A high incident rate is not a precursor or an indicator that an employer will suffer a higher frequency of injuries / illnesses the following year. These incident rates are lagging indicators—as the injuries and illnesses being factored have already occurred. These incident rates do however, offer the prudent employer an opportunity to review their safety and health management system/program (SHMS/P) and create benchmarks which can be used to identify deficiencies. Even if an employer has one or more years with incident rates lower than the BLS rates, an annual review of the SHMS/P should still occur, since low incident rates do not automatically equate to that employer having an effective SHMS/P.

The American National Standard Institute (ANSI) / American Industrial Hygiene Association (AIHA) consensus standard,  ANSI/AIHA Z-10 “Occupational Health and Safety Management Systems (OHSMS)” states that organizations should develop measures of performance that enable them to see how they are doing in preventing injuries and illnesses. It states, “Occupational injury and illness rates are a common yardstick for measuring effectiveness of an OHSMS, and they can play a valuable role. These rates, however, should rarely be the sole or primary tool to evaluate performance of an OHSMS…When injury indicators are the only measure, there may be significant pressure for organizations to “manage the numbers” rather than improve or manage the process…Incidents may be a symptom of a problem in the OHSMS.” James Reason writes in his book, “Managing the Risks of Organizational Accidents” that an unusually high incident rate is almost certainly the consequence of a “sick” system. And he writes that a low incident rate, which can be the case with many employers, reveals “very little about the likelihood of an organizational accident”, since accidents have multiple causal / latent factors such as “…poor design, gaps in supervision, undetected manufacturing defects or maintenance failures, unworkable procedures, clumsy automation, shortfalls in training, less than adequate tools or equipment—any may be present for many years before they combine with local circumstances and active failures to penetrate the system’s many layers of defenses.”