Q. With regards to recordkeeping for work-related injuries and illnesses, we use OSHA’s Form 300; however, we have not been maintaining the Form 301.

Are there circumstances when an employer does not have to complete this form for every incident or illness?

A. You do not have to keep OSHA’s Form 301 but you do need to keep something that is equivalent to it. That means the form or other document you use has to have the same information on it as the Form 301.

Many companies want to keep their own incident form instead of using the Form 301. Some companies use the “first report of injury form” for worker’s comp. You can use one of these forms, but be sure to compare to the 301 so you know what you decide to use contains all the same information. If it does, then it meets the requirement of “equivalent” form. If something is missing (for instance, the OSHA 300 Log #), then you can add it even if you just write it on your form.

I recommend that you keep some type of incident form for all incidents that occur in your workplace. That way you can track and  trend even minor cases.

OSHA’s definition of an equivalent form:

An equivalent form is one that has the same information, is as readable and understandable, and is completed using the same instructions as the OSHA form it replaces. Many employers use an insurance form instead of the OSHA 301 Incident Report, or supplement an insurance form by adding any additional information required by OSHA.

Resources

Injury & Illness Recordkeeping forms
An Overview: Recording Work-Related Injuries & Illnesses