OSHA Recordkeeping

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Employment Relations Division
Occupational Safety and Health Bureau
OSHA Recordkeeping
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• Just because the numbers are good doesnt mean
  anything. There are three ways to continuously
  improve performance numbers. One is to
  continuously improve processes, one is to get
  lucky, and the other is to lie. If you arent
  dedicated to improving processes, youre doing
  one of the other two.
• Dr. W. Edwards Deming Author and Consultant.

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• Identify the OSHA requirements for recordkeeping,
  posting and reporting
• Acquire an understanding of the OSHA 300, 300A
  and 301.

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• Required since 1971
• Key provisions of the OSHA rules for recording
  injury and illness cases
• 29 CFR 1904 new in 2002, changed in 2003 (hearing
  loss), and again in 2004 (form update)
• Rumored changes in 2010
• National Emphasis for 2009

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• The system is simpler and provides better
  resources than the old system
• Greater employer flexibility determining
  recordability
• Some aspects reduce ORIs, some increase ORIs
• Day counts are not comparable to previous years
  due to changes

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• If your company had 10 or fewer employees at all
  times during the last calendar year, you do not
  need to keep the injury and illness records
  unless surveyed by OSHA or BLS
• The size exemption is based on the number of
  employees in the entire company
• Include temporary employees who you supervised on
  a day to day basis in the count

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• All industries in agriculture, construction,
  manufacturing, transportation, utilities and
  wholesale trade sectors are covered
• In the retail and service sectors, some
  industries are partially exempt

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• Employees on payroll
• Employees not on payroll who are supervised on a
  day-to-day basis
• Exclude self-employed and partners
• Temporary help agencies should not record the
  cases experienced by temp workers who are
  supervised by the using firm

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• Keep a separate OSHA Form 300 for each
  establishment that is expected to be in operation
  for more than a year
• May keep one OSHA Form 300 for all short-term
  establishments
• Each employee must be linked with one
  establishment

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• Easily accessible information in a condensed
  format
• A thumbnail sketch of the things causing harm to
  employees
• Helps employers recognize hazards causing or
  likely to cause harm
• Helps inspectors focus their audits

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• OSHA's Form 300, the Log of Work-Related Injuries
  and Illnesses (replaced the OSHA 200)
  information on injuries and illnesses in a
  condensed format
• The 301 form (replaced the OSHA 101) detailed
  record of each case recorded on the 300 form
• Form 300A is the summary of work-related injury
  and illness cases. This is the form that is
  posted every year for the previous years log

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• The OSHA 301 Injury and Illness Incident Record
  provides detailed information about
• the affected worker,
• the injury or illness,
• the workplace factors associated with the
  accident,
• a brief description of how the injury or illness
  occurred.
• Equivalent workers' compensation First Report
  form or internal forms are okay, so long as all
  of the same information is included.

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• Summarizes entries from the Form 300 Log
• Post February 1 April 30 of the following year
• Gives employees an overview of the actual hazards
  in their workplace
• Contains totals for each column from the Form
  300, plus the average number of employees and
  total hours worked
• Certification of the data by a company executive
  is required.
• NOTE By law, the 300A must be signed by an
  executive of the company Not a designee.

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• Record every fatality, injury or illness that
  meets these criteria
• Work-related,
• A new case,
• Meets one of the general or specific recording
  criteria found in the regulation.
• The same requirements now apply to both injuries
  and illnesses.

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• Aggravation of a Pre-existing condition is work
  related and recordable when a work event or
  exposure causes one of the following (Presuming
  that this outcome would not have occurred without
  the work event or exposure)
• death
• loss of consciousness
• a day or days away from work, restricted work or
  job transfer
• medical treatment or a change in the course of
  medical treatment.

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• An injury or illness that occurs while an
  employee is on travel status is work-related if
  it occurred while the employee was engaged in
  work activities in the interest of the employer
• Home away from home
• Detour for personal reasons is not work-related

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• Injuries and illnesses that occur while an
  employee is working at home are work-related if
  they
• occur while the employee is performing work for
  pay or compensation in the home, and
• they are directly related to the performance of
  work rather than the general home environment

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• A case is new if
• The employee has not previously experienced a
  recordable injury or illness of the same type
  that affects the same part of the body or
• The employee previously experienced a recordable
  injury or illness of the same type that affects
  the same part of the body, but had recovered
  completely and an event or exposure in the work
  environment caused the signs and symptoms to
  reappear
• If there is a medical opinion regarding
  resolution of a case, the employer must follow
  that opinion

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• Cases occurring on the work premises are presumed
  to be work-related except when they involve
• Eating, drinking or preparing food or drink
• Common colds and flu
• Voluntary participation in wellness program,
  medical, fitness, or recreational activity
• Mental illness (unless employee voluntarily
  provides an opinion from a licensed health care
  professional stating condition is work related)
• Employee is at work as a member of the general
  public rather than as an employee.
• Symptoms surface at work but result solely from a
  non-work-related event or exposure.
• Doing personal tasks at work outside normal work
  hours.
• Grooming, self-medication, or intentionally
  self-inflicted.
• A motor vehicle accident on a company parking lot
  or company access road while commuting to or from
  work

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• Death
• Days away from work
• Restricted work or job transfer
• Medical treatment beyond first aid
• Loss of consciousness
• Diagnosis by a PLHCP as a significant injury or
  illness

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• Record if the case involves one or more days away
  from work
• Check the box for days away cases and count the
  number of days
• Do not include the day of injury/illness

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• Restricted work activity occurs when
• An employee is kept from performing one or more
  routine functions (work activities the employee
  regularly performs at least once per week) of his
  or her job or
• An employee is kept from working a full workday
  or
• A PLHCP recommends either of the above

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• Job Transfer
• An injured or ill employee is assigned to a job
  other than his or her regular job for part of the
  day
• A case is recordable if the injured or ill
  employee performs his or her routine job duties
  for part of a day and is assigned to another job
  for the rest of the day

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• Medical treatment is the management and care of a
  patient to combat disease or disorder
• It does not include
• Visits to a PLHCP solely for observation or
  counseling
• Diagnostic procedures
• First aid

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• Using nonprescription medication at
  nonprescription strength
• Tetanus immunizations
• Cleaning, flushing, or soaking surface wounds
• Wound coverings, butterfly bandages, Steri-Strips
• Hot or cold therapy
• Non-rigid means of support
• Temporary immobilization device used to transport
  accident victims

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• Drilling of fingernail or toenail, draining fluid
  from blister
• Eye patches
• Removing foreign bodies from eye using irrigation
  or cotton swab
• Removing splinters or foreign material from areas
  other than the eye by irrigation, tweezers,
  cotton swabs or other simple means
• Finger guards
• Massages
• Drinking fluids for relief of heat stress

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• All work-related cases involving loss of
  consciousness must be recorded

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• Includes all punctures, cuts and lacerations
  caused by needles or other sharp objects
  contaminated (or presumed contaminated) with
  blood or OPIM
• Such injuries may later cause diseases like AIDS,
  hepatitis B and hepatitis C and must be monitored
• Does not require the recording of all cuts and
  punctures. (e.g. A cut made by a knife or other
  sharp object not contaminated by blood or OPIM
  would not be recordable if only first aid was
  required)

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• CURRENT RULE

OLD RULE

• 10 dB loss from original or revised baseline in
  either ear ONLY when accompanied by an overall 25
  dB shift from audiometric zero (normal hearing)

• 25 dB loss from original or revised baseline in
  either ear

Both based upon average of audiometric results at
2000, 3000 4000 Hz Both allow age adjustments
according to the Hearing Conservation Standard
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• MSD cases like carpal tunnel syndrome are
  recordable on the 300 log if they meet general
  recording criteria
• Employer retains flexibility to determine whether
  an event or exposure in the work environment
  caused or contributed to the MSD

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• Must record cases when there is a known exposure
  to tuberculosis and an employee develops a
  tuberculosis infection.
• Must record a case on the OSHA 300 Log whenever
  an employee is medically removed under the
  medical surveillance requirements of any OSHA
  standard.
• Must be recorded as a case involving days away
  from work or as a case involving restricted work
  activity, depending upon the removal requirements

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• Count days away or days restricted or
  transferred for every day after the date of
  incident or onset (the day of injury or illness
  is not counted)
• Count all calendar days, including weekends,
  holidays, shutdowns and vacations
• There is a limit on how long employers are
  required to track cases. Days away or days of
  restriction do not have to be counted beyond 180
  days, total for both categories

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• Employers must inform employees of how to report
  an injury or illness.
• Employers are prohibited from discriminating
  against employees for reporting injuries and
  illnesses.
• Employees may access the 301 forms for their own
  cases
• Employee representatives now have a right to view
  the right-hand column of the OSHA 301
• Employees, former employees, and employee
  representatives (union, attorney, physician,
  etc.) have a right to view a copy of the Log

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• Employers must withhold the employee's name from
  the OSHA log for "privacy concern cases"
• A separate list of case numbers and employee
  names must be provided to OSHA upon request
• Privacy concern cases include
• Intimate body part or reproductive system
• Resulting from a sexual assault
• Mental illness
• Communicable diseases (HIV, hepatitis,
  tuberculosis)
• Contaminated Needlestick and sharps injuries
• Other merited employee requests

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• The Form 300A must be certified at the end of
  each year
• It must be posted from February 1 until April 30
  of the year following
• A company executive must certify the accuracy of
  the data

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• Must report fatalities and hospitalizations of
  three of more employees to OSHA within 8 hours.
• The report must be made to the OSHA area office
  or the toll free number 1-800-321-6742 (OSHA).
• Clarifications in the rule relating to reporting
• Employers must report fatal heart attacks that
  occur at work
• Employers do not have to report motor vehicle
  accidents that occur in a public street
• Employers do not have to report public transport
  accidents
• Even when accidents are not reportable, they are
  recordable if they meet OSHA's recordability
  criteria.

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• Days Away From Work
• Days of Restricted Work Activity
• Job Transfer
• Formula
• Number of entries in Column H x 200,000/Number of
  hrs worked by all employees DART incidence rate

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• Incidence rate for all recordable cases of
  injuries and illnesses
• Formula
• Total number of injuries illnesses x
  200,000/Number or hrs worked by all employees
  Total recordable case rate

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• Information is constantly changing bookmark and
  refer to this webpage
• www.osha.gov

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