Special Topics in Safety Management

OSHA Recordkeeping Lapses: Why Do They Happen; What Should You Do?

When lapses in OSHA recordkeeping occur, the fault usually is with line managers. Here’s why it happens and how to keep them involved.

Yesterday’s Advisor began a discussion of OSHA recordkeeping, starting with the 300 Log program, the basic form that requires reporting all workplace or workplace-related injuries and illnesses that cross OSHA’s threshold. The dimensions of that threshold was described in detail yesterday and need not be repeated, but generally, any harm to a worker that needs more than first aid must be reported.

The 300 Log program, however, is just the tip of the iceberg when it comes to OSHA recordkeeping requirements.

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Courtesy of BLR’s OSHA Compliance Encyclopedia on CD, here are other safety-related matters with a recordkeeping requirement. Depending on the nature of your business, you’re likely to have to comply with one or more of them.

  • Written hazard communication plan

  • Written contingency plan for emergencies

  • HAZWOPER safety and health programs

  • Training records (who was trained, in what, and when)

  • Medical surveillance records (for lead, asbestos, and other substances)

  • Air sampling or other environmental monitoring results

  • Equipment and process testing, inspection, and maintenance

  • Respirator testing, training, and use

  • Noise exposure monitoring and hearing conservation program

  • Forklift evaluation and training

  • Hazard assessments for determining PPE needs

    Quite a list, isn’t it? With potential fines of up to $10,000 for some violations, and if OSHA feels, say, that the misstep was willful, up to 6 months in jail.

    Few safety managers willfully neglect to keep records. More often, the problem is the line managers or supervisors they depend on for reporting not fulfilling their responsibilities. OSHA Compliance Encyclopedia lists reasons for these lapses. They include:

  • Lack of time, due to production pressures or the chaos that surrounds a serious injury, when getting the injured help has priority over paperwork

  • Unclear responsibility as to whose job it is to keep the records

  • Lack of training on what records to keep and how to keep them

  • Desire to keep a good safety profile, especially when there may be incentives involved, or even a “days since our last accident” record to beat

    The keys to overcoming these problems are training and management. “Keep managers actively involved,” say the OCE experts. “Be sure they check the records regularly.”

    They also advise making use of your insurance carrier’s loss control service. “They can usually provide both initial and regular refresher training,” says OCE.

    These answers were drawn from BLR’s OSHA Compliance Encyclopedia on CD. It’s a new tech version of a reference safety professionals have depended on for decades, that literally is, as our marketing brethren like to say, “everything you need to know about OSHA compliance, in the palm of your hand.”

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