The Danger of Over-Reporting on your OSHA 300 Forms
December 1st 2020
- Best Practices
- Compliance
- OSHA Regulations
Per OSHA’s regulation 29 CFR 1904, employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses. The information is recorded, in detail, on the OSHA 300 forms. Some establishments with 250 or more employees are required to electronically submit information from their OSHA Form 300A (a summary of the 300 Form). OSHA tracks this information with the goal of preventing accidents in the future.
Recordable or Not?
It is particularly important for companies to understand what is considered “recordable”. For example, accidentally reporting an injury that did not occur on the jobsite or reporting a cut or scrape that isn’t a recordable accident could have dire consequences. Or a company might report every accident, recordable or not, in an effort to avoid an OSHA fine. This could be especially dangerous for a small, family-owned business. If a company isn’t sure about recording an incident and decides not to, they can document it in good faith at a later date. However, when in doubt, it is recommended that a company representative consult an expert or call their local OSHA office.
For more information about OSHA’s record keeping requirements visit OSHA’s website at – https://www.osha.gov/recordkeeping/
It is important to document these serious injuries and illnesses accurately. Over-reporting injuries and illnesses can negatively impact a company’s TRIR and EMR and it will appear that the company is not working in a safe manner.
What is TRIR?
Total Recordable Incident Rate or TRIR is a mathematical computation that takes into account how many OSHA recordable incidents a company has per number of hours worked and this number can affect the fate of a company.
Below is the formula to calculate TRIR (top line divided by bottom):
(Number of OSHA recordable incidents) x 200,000
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(Total number of hours worked)
A perfect TRIR score is zero, this means that the company had no OSHA recordable incidents. The higher the TRIR number the more “unsafe” the company will appear to be. Even one OSHA recordable can put a company’s TRIR above the industry average. And if a company’s TRIR gets too high, some companies may not want to hire them to do work for them in fear that they will have an accident on their jobsite.
What is EMR?
Experience Modification Rate or EMR is the number used by insurance companies to measure the cost of injuries in the past and the predication of future accidents or risk of a company. The lower the EMR of a business, the lower their worker compensation insurance premiums will be. An EMR of 1.0 is considered the industry average.
When a business has an EMR greater than 1.0 it means the company has had to pay for one or more worker compensation claims. To lessen the insurance company’s risk, they raise the worker compensation premiums. The increase stays with that company for 3 years. Additionally, an increase in insurance rates can make a company less competitive due to higher operating costs.
Summary
In short, when a company invests in a strong safety program they will prevent accidents and reduce costs. No accidents means no OSHA recordables on the 300A Form. Understanding OSHA’s recordable requirements and reporting them accurately is very important for a number of reasons:
- A higher than industry average TRIR indicates your company is less safe than most. Many hiring clients will review TRIR when selecting contractors/vendors for new projects, and they usually prefer to work with the safest (less risky) businesses
- The lower your EMR, the lower your worker compensation insurance premiums will be
- Most clients working with third-party auditors such as Avetta®, *ISNetworld®, Veriforce®, ComplyWorks® and others include EMR and TRIR among their criteria for qualification
How to get help with OSHA 300 forms?
Safety Services Company is dedicated to helping customers meet compliance requirements for OSHA and third-party auditors, including guidance for how to manage record keeping. When it comes to completing OSHA 300 forms, we want to see you get it right first time, so we’ve put together a quick reference guide to make things easy. Download for free using the link below –
Download OSHA 300 Quick Reference Guide
In addition, we can provide more in-depth training either online or as a self-contained DIY training kit. Just click below for more info –
Still have questions, or need help reviewing the forms? Please don’t hesitate to give us a call. Our safety advisors are happy to help!