OSHA Forms
TOSHA Recordkeeping Forms
The OSHA 200 Log and OSHA 101 Supplemental Record are obsolete. Tennessee cities required to maintain TOSHA injury and illness records must use the current OSHA/TOSHA recordkeeping forms, or equivalent forms:
- OSHA Form 300 — Log of Work-Related Injuries and Illnesses.
- OSHA Form 300A — Summary of Work-Related Injuries and Illnesses.
- OSHA Form 301 — Injury and Illness Incident Report.
The city may use paper forms or an electronic recordkeeping system. An electronic or computer-generated form is permitted if it contains the same information as the corresponding OSHA form, is as readable and understandable, and is completed using the same instructions as the OSHA form it replaces.
Completing the Forms
For each establishment, the city must enter the establishment information at the top of the OSHA/TOSHA 300 Log. The city must then record each work-related injury or illness that is a new case and meets the applicable recordkeeping criteria.
For every recordable case entered on the OSHA/TOSHA 300 Log, the city must also complete OSHA Form 301 or an equivalent incident-report form. The form must contain the information required by OSHA Form 301 and be completed according to the same instructions.
The city must enter each recordable injury or illness on the OSHA/TOSHA 300 Log and complete the OSHA 301 Incident Report, or equivalent form, within seven calendar days after receiving information that a recordable injury or illness occurred.
At the end of each calendar year, the city must review the OSHA/TOSHA 300 Log for completeness and accuracy, correct any deficiencies, prepare the OSHA/TOSHA 300A Annual Summary, and have the summary certified by a company executive or other authorized official. The annual summary must be posted in a conspicuous location where employee notices are customarily posted from February 1 through April 30 of the following year.
Privacy-Concern Cases
The city must protect an employee’s privacy in a privacy-concern case. The employee’s name must not be entered on the OSHA/TOSHA 300 Log for:
- An injury or illness involving an intimate body part or reproductive system.
- An injury or illness resulting from sexual assault.
- A mental illness.
- HIV infection, hepatitis infection, or tuberculosis.
- A needlestick injury or cut from a sharp object contaminated with another person’s blood or other potentially infectious material.
- Another illness case in which the employee voluntarily requests that the employee’s name not be entered on the log.
For a privacy-concern case, the city must enter “privacy case” instead of the employee’s name on the OSHA/TOSHA 300 Log. The city must maintain a separate, confidential list that connects the case number to the employee’s name. This list is used to update the record or provide information to authorized government officials when required. The city must protect the list and other medical information from unauthorized disclosure.
Retention and Updates
The city must retain the following records for five years after the end of the calendar year covered by the records:
- The OSHA/TOSHA 300 Log.
- The privacy-case list, if one exists.
- The OSHA/TOSHA 300A Annual Summary.
- The OSHA/TOSHA 301 Incident Report forms, or equivalent forms.
During the five-year retention period, the city must update the OSHA/TOSHA 300 Log to add newly discovered recordable cases and reflect changes in the classification of previously recorded cases. If the description or outcome of a case changes, the city should line through the original entry without obscuring it and enter the updated information.
The city is not required to update the OSHA/TOSHA 300A Annual Summary or the OSHA/TOSHA 301 Incident Report after completion, although it may do so voluntarily.
Records Access
The city should maintain OSHA/TOSHA injury and illness records in a secure, retrievable location. Access to the OSHA/TOSHA 300 Log and 301 Incident Reports must be handled in accordance with applicable employee, former-employee, authorized-representative, and government-inspection access rules, while protecting the confidentiality of privacy-concern cases and medical information.