Federal injury recordkeeping forms

Agencies must enter the employee's OPM job series number and the employee's job title in Column (c). This is required by 1960.73(a).

• Enter both the numeric OPM job series and a clear job title for each recordable case.
• This rule applies when using the OSHA Form 300 or an equivalent log as stated in 1960.73(a).

You must enter a capital "V" before the OPM job series number in Column (c) for uncompensated volunteers. This labeling requirement is set out in 1960.73(b).

• The "V" flags the worker as an uncompensated volunteer.
• After the "V", include the applicable OPM job series number and job title as required by 1960.73(a).

Each agency must calculate the total number of hours worked by uncompensated volunteers. This is required by 1960.73(c).

• Sum the hours that uncompensated volunteers actually worked for the agency during the relevant recordkeeping period.
• Keep that total available as part of the agency's recordkeeping for volunteer exposures and for any internal calculations that use hours worked.

Yes — when using OSHA Form 300 or an equivalent log, the agency must still enter the OPM job series number and job title in Column (c). The requirement is explicit in 1960.73(a).

• An equivalent form must provide a Column (c) field (or clearly comparable field) to record the OPM job series and job title.
• For uncompensated volunteers, the agency must still prefix the series number with a "V" as required by 1960.73(b).

Yes — when recording the injuries and illnesses of uncompensated volunteers, the agency must enter a "V" before the OPM job series number in Column (c) and treat the case on the log accordingly. This is required by 1960.73(b).

• Also calculate and retain the total hours worked by uncompensated volunteers as required by 1960.73(c).
• Follow the usual Form 300 instructions for documenting case details, while flagging the worker with the leading "V".

Yes — 1960.73(b) specifies entering a "V" before the OPM job series number, which should be entered as shown (an uppercase "V"). See 1960.73(b).

• Use the capital letter "V" exactly as described to consistently identify uncompensated volunteers on the log.

Column (c) must reflect the employee's current OPM job series number and job title as required by 1960.73(a).

• If a worker's official job series or title changes, the agency should record the correct series number and title that apply to that worker for the time of the recorded injury or illness.
• Maintain accurate records that match the agency's HR/OPM classifications to meet 1960.73(a).

Yes — 1960.73(c) expressly requires each agency to calculate the total number of hours worked by uncompensated volunteers, so those hours must be included in the agency's volunteer-hours totals.

• Keep a running or periodic total of all uncompensated volunteer hours so the agency can document the number required by 1960.73(c).

The "V" should appear immediately before the OPM job series number in Column (c) (or the equivalent field on a local log), as required by 1960.73(b).

• On an equivalent form, make sure the placement of the "V" is clear so reviewers understand the record identifies an uncompensated volunteer in accordance with 1960.73(b).

Record the case on the Form 300 (or equivalent) with a leading "V" before the OPM job series number in Column (c), and separately calculate and retain the total hours worked by uncompensated volunteers as required by 1960.73(b) and 1960.73(c).

• Use the Form 300 case entry fields per normal instructions, but prefix the series with "V".
• Maintain the aggregated volunteer-hours total to demonstrate compliance with 1960.73(c).

OSHA's "Recordkeeping enforcement procedures" memorandum provides guidance on enforcement of recordkeeping requirements and related employee-involvement rules; you can consult that interpretation for enforcement context: https://www.osha.gov/laws-regs/standardinterpretations/2016-11-10. For the specific volunteer and Column (c) rules see 1960.73.

• The enforcement memorandum discusses interim procedures for new recordkeeping provisions and helps explain how OSHA approaches investigations of recordkeeping rules (see https://www.osha.gov/laws-regs/standardinterpretations/2016-11-10).
• For the precise form entries required for volunteers and employees, rely on 1960.73(a)-(c).

No — 1960.73(b) specifically addresses "uncompensated volunteers," who must be marked with a leading "V"; compensated employees should be recorded with their regular OPM job series number and job title per 1960.73(a).

• If the worker receives pay for the work, they are not an "uncompensated volunteer" and should not be prefixed with "V" under 1960.73(b).

If an agency cannot identify an appropriate OPM job series number for a worker, the agency should consult its human resources or OPM classification office to determine the correct series and job title before completing Column (c), consistent with the requirement to enter the OPM job series number and job title in 1960.73(a).

• Accurate series and title entries help ensure consistency and compliance with 1960.73(a).

The requirements are part of 29 CFR Part 1960, Basic Program Elements for Federal Employee Occupational Safety and Health Programs; see the 1960 overview and the specific 1960.73 Federal agency injury and illness recordkeeping forms.

• The 1960.73 page contains the text of subsections (a), (b), and (c) explaining job series entries, volunteer marking, and volunteer-hours totals.