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New OSHA Recordkeeping Rules

The Occupational Safety and Health Administration (OSHA) requires employers to keep track of serious work-related injuries and illnesses.  The information aids employers, workers, and OSHA to:

  • evaluate the safety of a workplace,
  • understand industry hazards, and
  • implement worker protections to reduce and eliminate hazards in preventing future workplace injuries and illnesses.

Currently employers with more than ten employees are required to keep a record of serious work-related injuries and illnesses. Records should be kept on OSHA Forms:

  • 300 – Log of Work-Related Injuries and Illnesses,
  • 301 – Injury and Illness Incident Report, and
  • 300A – Summary of Work-Related Injuries and Illnesses.

All recordable injuries and illnesses must be recorded within seven-days of the employer learning of the occurrence. Injury and illness is defined as an abnormal condition, not an exposure unless it results in signs or symptoms.  Severity criteria that prompts a recording includes:

  • death,
  • loss of consciousness,
  • days away from work,
  • restricted work activity or job transfer, and
  • medical treatment beyond first aid.

Other recording criteria may include:

  • hearing loss,
  • tuberculosis,
  • medical removal,
  • needle stick and sharps injuries, and
  • significant diagnosis of an injury or illness.

There are certain low-risk industries (refer to OSHA’s website) who are exempt from the OSHA rules. Currently, employers are not required to file their forms with OSHA unless they are specifically asked by OSHA, the Bureau of Labor Statistics (BLS), or a state reporting agency under the authority of OSHA, or BLS, requiring them to do so. Simple first aid or minor injuries do not need to be recorded. However, all fatalities must be reported within eight-hours and any amputation, loss of an eye, or hospitalization of a worker must be reported within 24-hours.

From February 1st through April 30th of each year, employers must post Form 300A – Summary of Work-Related Injuries and Illnesses which were recorded during the previous year.  The report should be removed after the expiration date, or employers may face fines for having the document posted outside of the designated timeframe.  All records should be maintained at the worksite for at least five-years.  If requested, employers must provide copies of the records to current and former employees, or their designated representatives.

Effective 12/1/17, OSHA, will require certain employers to electronically submit injury and illness data that they are already required to record on their onsite OSHA injury and illness forms.  The new reporting requirements will be phased in over two-years. The Form 300A, Form 300 and Form 301 will be electronically submitted at differing intervals during the next two-years. As of the writing of this article establishments with 250 or more employees in industries covered by the recordkeeping regulations and establishments with 20 – 249 employees in certain high-risk industries (refer to OSHA’s website) will be required to submit their information electronically.  To read the full OSHA Recordkeeping regulation 29 CFR 1904 visit OSHA’s website at www.osha.gov.

For additional information on OSHA recordkeeping rules, please contact us at www.newfocushr.com.

Source: Occupational Health and Safety Administration (OSHA) website at www.osha.gov.

Written by:  Kristen Deutsch, M.B.A., CCP






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