If your company employs 250 or more workers (or fewer, depending on your industry) and is required to keep injury and illness records, the deadline to submit your OSHA Form 300A is March 2, 2021. While most of the basics for electronically reporting this data via OSHA’s Injury Tracking Application (ITA) remain the same this year, there are a few details that may trip up even veteran environment, health, and safety (EHS) managers. Here are tips for getting it right.
When it comes to OSHA recordkeeping and reporting, there’s almost always opportunity for error. One of the most common is discerning when an incident is actually recordable and when it is simply first aid (more on that in this previous article). But while this is a year-round recordkeeping issue, there are a few key aspects of safety data that often cause confusion when it comes time to report data to OSHA in March. Three in particular are:
The types and average number of employees included in OSHA 300A logs.
The total number of hours worked by all employees.
Calculating an organization’s incident rate.
Here we’ll take a closer look at each of these calculations, some of which directly affect others, to take the guesswork out of your 2021 safety data reporting.
The Types—and Average Number—of Employees
First of all, don’t forget your temporary workers in addition to any full- or part-time regular workers! Safety recordkeeping responsibility is determined by which party is providing day-to-day supervision over the employee, which in most cases is the host employer. Unless your staffing agency sends its own supervisor who is directly in charge of the day-to-day work of temporary employees, any injury and illness data related to these workers must be logged on your OSHA 300A.
You are also required to report the “average number” of employees. While there are several resources (including this one from the U.S. Bureau of Labor Statistics) to calculate this number, it can still sometimes be confusing. The formula is:
The average number of employees = The total number of employees paid in all pay periods ÷ The total number of pay periods in the year
This isn’t necessarily as straightforward as it sounds, however. If you employed the same 250 people all year on a biweekly pay schedule (i.e., 26 pay periods), you do not divide 250 by 26 to get an average of 9.6 employees. It is the total number of employees in all pay periods—therefore, you must multiply 250 by 26 … and then divide it by 26 again to arrive at an average of 250 employees.
This, of course, is obvious in such a simple example where numbers are constant. But organizations’ sizes fluctuate with turnover or in industries where employment shrinks or expands seasonally—for these employers, one pay period may include 50 employees, then the next 10 periods include 100 employees, and then the next several periods include 75, etc. Ensure that your records accurately note the total number of employees for each pay period throughout the year to make the above formula easier to apply when OSHA reporting is due.
Total Hours Worked
Your total hours worked data are essential for determining your incident rate (more on that in a moment). However, it’s important to note that OSHA doesn’t want this number to include time off, whether it’s vacation, sick leave, or holidays, paid or unpaid. They literally are only interested in the hours worked. After all, if an employee is injured on vacation, it wouldn’t be recordable. However, you also must remember all of your temporary and part-time workers, as mentioned above.
Find your total hours worked in three steps:
Determine your number of full-time employees over the course of the year.
Multiply your number of full-time employees by the number of hours worked by said employees. With a 40-hour workweek, the resulting number of hours is usually in the neighborhood of 2,000 hours, but you should take into account your organization’s unique time off policy, if necessary.
Add to this number any overtime hours. Also add in all hours worked by temporary, seasonal, or part-time employees.
These steps will provide you with the total hours worked for all employees during the year.
Calculating Your Incident Rate
With your hours worked data now on hand, it’s time to determine your organization’s incident rate, also commonly referred to as the Total Recordable Incident Rate (TRIR). Here is a simple formula to apply:
TRIR = The total number of injuries/illnesses ÷ Total hours worked by all employees x 200,000 hours
Why multiply by 200,000 hours at the end? That figure represents the hours that 100 employees would work during a typical year made up of 40-hour workweeks with 2 weeks off per year. By incorporating this into the formula, it creates TRIRs that can be used to compare injury rates within any industry, whether a specific facility has 10 workers or 10,000. This ability to quickly compare incident rates can help prompt the creation of new health and safety guidance and/or regulation as well as direct more effective or targeted enforcement efforts.
Let Software Do the Work for You
All of these considerations can be complex, especially for midsize to large organizations, and every EHS manager should be looking to work smarter, not harder. With a software solution, you can ensure that your records are accurate and properly calculated.
Dakota Software’s recent updates directly address the issues addressed in this article, combining your hours worked data with injury and illness records from your various locations and automatically calculating and populating your OSHA 300A report and OSHA 300 logs, making your safety data readily exportable for required OSHA electronic reporting. While many of the formulas described above are simple enough, a properly implemented automated system can save time and reduce uncertainty.
In short, technology can provide you with the confidence that what you’re sending to OSHA is correct—a win-win for both your organization and workplace safety efforts nationwide.