OSHA Recordkeeping & Electronic Reporting – Special Focus on Senior Living & Social Services

Healthcare, Property & Casualty, Risk, Senior Living & Social Services

Most senior living and social service providers will need to post their 2020 OSHA Summary (Form 300A) from February 1st to April 30th at each establishment (physical location). There are some industries that are Partially Exempt. Most notable are the following industries:

  • 6111: Elementary and Secondary Schools
  • 6244: Child Day Care  
  • 8661: Religious Organizations

“Religious organizations” is limited to establishments like churches, convents, temples, etc. Nursing homes, assisted living facilities, or second hand stores maintained by religious organizations should be classified according to their primary activity.

In addition, employers may be required to submit OSHA 300A summaries electronically to OSHA. All employers who have more than 250 employees at an establishment and employers with more than 20 but less than 250 employees that OSHA has included in Appendix A will need to electronically submit their OSHA 300A by March 2nd. Appendix A includes (but is not limited to) the following industries:

  • 6231: Skilled Nursing     
  • 6232: Residential for intellectual and developmentally delayed, mental health and substance abuse (AFH and CBRFs)
  • 6233: Retirement communities including assisted living for elderly
  • 6239: Other Residential care facilities including child group foster homes, halfway houses and group homes
  • 6243: Vocational Rehab Services – work experience centers, job training (sheltered workshops) except schools

Please note: the following industries are subject to posting the summary but not required to electronically submit unless they have more than 250 employees at an establishment:

  • 621610: Home health and residential hospice
  • 624120: Adult Day Care, Home care non-medical (supportive home care), senior citizens center
  • 624110: Foster Care Placing Agencies
  • 624190: Other Individual and Family Services – Community Action Service Agencies, Family Social Services


Only record COVID-19 as an illness on the OSHA log if you have determined work-relatedness through a thorough investigation and the employee experienced days away from work and/or medical treatment beyond first aid. If the employee did not have medical treatment beyond first aid and was able to work remotely (i.e. no lost time), the illness may not need to be recorded on the Log. OSHA’s guidance recognizes that in areas where there is ongoing community transmission, employers may have difficulty determining whether workers who contracted COVID-19 did so due to exposures at work.

Key Reminders for Senior Living and Social Services Organizations

  • OSHA logs are completed at the establishment (location) level
  • First Aid vs. Medical Treatment; only those injuries in which medical treatment is provided is recordable.
  • Even if the employee is injured or acquires an illness at work, there are nine exceptions to work-relatedness where it would not be recordable.
  • Be sure to include all hours worked from all contracted employees including temp agencies into the total hours worked.
  • Days away, restricted or job transfer includes all days (i.e. weekends, holidays and days the individual was not scheduled to work)
    • Stop counting at 180 days
    • Stop counting if individual leaves the organization unrelated to the injury/illness

If you’re unsure if the employee injury or illness is recordable, refer to this OSHA decision tree. Contact your M3 Account Executive with further questions.

Length: 1 hour + 15 minutes

Supplemental materials:

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