OSHA News

Solid Recordkeeping Advice Can Keep You Off OSHA's Radar

(Jan 08, 2008)-- Every year, the U.S. Occupational Safety and Health Administration sends letters to approximately 80,000 employers across the country requesting their injury and illness data from the previous year. This is reported in what's known in the industry as the 300A Summary of Work-Related Injuries and Illnesses. From this data, OSHA picks 14,000 workplaces with the highest incident rates. Not only are these workplaces listed on OSHA's website, but from the 14,000 workplaces listed, 4,500 are then targeted for wall-to-wall inspections.

"As we begin a new year," notes Julie Nussbaum, a compliance subject matter expert with J. J. Keller & Associates, "I cannot overestimate the importance of accurate recordkeeping. Too many employers record injuries that don't need to be recorded ... skewing their incident rate and making their safety performance appear questionable."

Nussbaum says it's critical for employers to become familiar with OSHA requirements and document only those cases that meet OSHA's recordability criteria. She offers the following three pieces of advice for accurate OSHA 300 recordkeeping.

#1: Learn about OSHA's injury and illness recordkeeping exemptions

"All employers under OSHA jurisdiction are covered by the 1904 recordkeeping regulations," says Nussbaum, "however, there are some exceptions. Certain industries such as retail, service, finance, insurance and real estate have low incident rates (at or below 75% of the national average) and do not have to keep injury and illness records. The same is true if a company had ten or fewer employees at all times the previous year." Nussbaum cautions that these exceptions fall under federal requirements and suggests employers check if there are any additional state requirements.

#2: Brush up on how to record OSHA recordable days

According to Nussbaum, employers need to count all calendar days the employee is off work or on restricted duty/job transfer. She states, "You need to count all calendar days that employees were unable to perform their regular jobs, regardless of whether they were scheduled to work. This includes weekends, holidays and vacation days." "You don't," she continues, "need to count the first day. Start counting on the day after injury occurred or illness began. And keep in mind OSHA's provision that allows you to cap the count at 180 days total for any one case."

#3: Know the difference between recordable and non-recordable cases

Nussbaum says three key elements must be met in order for an injury or illness to be recordable. First, it must be work-related. This means that an event or exposure in the workplace causes or contributes to an injury or aggravates a pre-existing condition. Second, it must be a new case, which means the employee hasn't had a recordable injury or illness of the same type to the same part of the body. Nussbaum explains that it is also considered a new case if the employee has completely recovered from a previous recordable injury/illness (that is, all signs and symptoms have disappeared) and a workplace event causes symptoms to reappear.

Finally, in order for an injury or illness to be recordable, it must meet OSHA's general or specific recording criteria. "OSHA currently lists seven general and five specific types of injuries and illnesses that make a case recordable," says Nussbaum. "All others are not recordable."

Share or bookmarklet this web page at: