When OSHA inspectors arrive at your workplace, the first thing they’ll want to see are your injury and illness records. And, although the agency’s recordkeeping rules may seem like just another administrative headache, the fact is that those records are a vital tool in promoting worker safety. Used in conjunction with the agency’s annual reports, you can see how your organization’s safety record stacks up against others in your industry—and what areas of your operation need attention.
OSHA has required employers to keep injury and illness records since 1971, the year the agency was formed. Today we’ll review some key elements of the rules, using information from the recordkeeping section of the OSHA website. You should refer to that website for the most up-to-date information on recordkeeping requirements.
Purpose and History
Injury and illness records are critical indicators both for employers and for OSHA. They tell you how you’re doing in your efforts to keep workers safe. And they pinpoint weaknesses—breakdowns in machinery, inadequate personal protective equipment, failures in communication, insufficient training, etc. When a worker gets sick or hurt, something has gone wrong. As an employer you need to look at those cases to see if you can take action to prevent future problems.
Last year OSHA levied more than $825,000 in recordkeeping-related penalties. Don’t become the next victim. Join us March 27 for a special audio conference, OSHA Recordkeeping: Beyond the OSHA 300 Logs. Find out more.
But there is also great value in reviewing the records as a whole to identify patterns and trends. What’s happening in specific departments and across your facility? How does your injury and illness experience stack up against others in your industry? Is it clear that your employees understand the need to wear protective equipment and follow safety rules? Asking these questions—and taking action in response to the answers—can prevent future injuries and illnesses and improve a company’s bottom line.
In 2001, OSHA significantly revised its recordkeeping rules, saying it wanted to improve the data, make recordkeeping simpler for employers, maximize the use of computers and technology, improve employee involvement and protect the privacy of the injured or ill worker.
Who is Covered?
When it comes to OSHA recordkeeping, the first question an employer needs to ask is, “Am I covered?” To begin with, every employer, regardless of size or industry, must orally report any incident that involves the death of a worker and/or the hospitalization of three or more workers. You must call your local OSHA office or 1-800-321-OSHA within eight hours of the incident. You don’t have to report most highway or commercial carrier accidents, but you must report fatal heart attacks that occur at work.
If you have 10 or fewer workers, you normally do not need to keep injury and illness records. Remember, though, to include temporary employees under your direct supervision in that count. And if you’re in one of the exempt low-hazard industries, you don’t have to keep records unless OSHA or BLS asks you in writing to participate in their annual surveys.
What Injuries and Illnesses Are Covered?
Second, you need to know what to count. The injuries and illnesses you record must be new cases that are work-related. That includes preexisting conditions that are significantly aggravated by workplace events or exposures.
What do you actually record? Injuries and illnesses that result in:
- Death
- Days away from work
- Restricted work or transfer to another
- Medical treatment beyond first aid
- Loss of consciousness
- Significant injury or illness diagnosed by a physician or other licensed healthcare professional
OSHA’s at the door—Are your records complete and up to date? Are you sure? Join us March 27 for an audio conference that will lead you through the OSHA recordkeeping maze. Find out more.
What Is NOT Covered?
OSHA has a list of exceptions for problems that are not considered work-related. The rule makes it clear that employers don’t have to record cases involving eating foods and drinking beverages, common colds and flu, blood donations, and exercise programs. In addition, mental illness will not be recorded unless the employee voluntarily provides the employer with an opinion from an appropriate licensed healthcare professional stating that the employee’s mental illness is work-related. But some injuries to employees doing work at home or while traveling on business are counted.
You also don’t have to record injuries or illnesses treated through first aid, such as taking aspirin, getting a tetanus shot, applying a butterfly bandage, draining a blister, wearing a finger guard, etc. For recordkeeping purposes, first-aid cases are not recordable. The rule provides an absolute list of what is first aid. If a treatment is NOT on the list, it MUST be considered medical treatment (20 CFR 1904.7(b)(5)(ii)).
Tomorrow we look at OSHA’s injury and illness forms, and we’ll invite you to an upcoming audio conference on how to comply with—and take the pain out of—the recordkeeping rules.
Your Safety Daily Advisor for March 9 contains the following: “orally report any incident that involves the death of a worker and/or the hospitalization of three or more workers”
The law has changed and it is now necessary to orally report any incident that involves the death of a worker and/or the hospitalization of one or more workers.