OSHA Recordkeeping

As part of your tracking process, you must comply with OSHA s recordkeeping requirements for occupational injuries and illnesses. Any occupational illness which has resulted in an abnormal condition or disorder caused by exposure to envirorrmental factors, which may be acute or chronic due to irrhalatiorr, absorption, ingestion or direct contact with toxic substances or harmful agents, and any repetitive motion injury is to be classified as an illness. All illnesses are recordable, regardless of severity. Injuries are recordable when  

An on-the-job death occurs (regardless of length of time between injury and death). 

The worker receives medical treatment beyond first aid. 

Most employers with more than ten employees are required to complete the Supplementary Record of Occupational Injuries and Illnesses (OSHA 101) or a comparable form and retain it for five years as well as complete the Log and Summary of Occupational Injuries and Illnesses (OSHA 200 log) and post it yearly from February 1 to March 1. The OSHA 101 and 200 log are the tracking records, which must be kept for compliance with OSHA regulations. 

Many companies conduct accident investigations and keep accident records and other data on the company s safety and health inilialives. Ifa company has a sufficient number of accidents/incidents and enough detail in their occupational injuiy/illness investigation data, the company can begin to examine trends or emerging issues relevant to their safety and health intervention/prevention effort. The analysis ofthis data can be used to evaluate the effectiveness of safely and health at various workplaces, jobsites, or for groups of workers. The safety and health data can be used to compare your company to companies that perform similar work, employ a comparable workforce, or compete in the same kind and size of market on a state, regional, national, or international basis. 

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA), THE REGULATION AND RELATED INTERPRETATIONS FOR RECORDING AND REPORTING OCCUPATIONAL INJURIES AND ILLNESSES, RECORDKEEPING HANDBOOK, OSHA3245-01R (U.S. DEPARTMENT OF LABOR, DIRECTORATE OF EVALUATION AND ANALYSIS, OFFICE OF STATISTICAL ANALYSIS, 2005) 

Employers are responsible for providing a safe and healthfnl workplace for their employees. OSHA s role is to assure the safety and health of America s workers by setting and enforcing standards providing training, ontreach, and education establishing partnerships and encouraging continnal improvement in workplace safety and health. For more information, visit www.osha.gov. 

This handbook provides a general overview of a particular topic related to OSHA regulation. It does not alter or determine compliance responsibilities in OSHA standards or the Occupational Safety and Health Act of 1970. Because interpretations and enforcement policy may change over time, you should consult current OSHA administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the Courts for additional guidance on OSHA compliance requirements. 

This publication is in the public domain and may be reproduced, fully or partially, without permission. Source credit is requested but not required. 

This information is available to sensory impaired individuals upon request. Voice phone (202) 693-1999 teletypewriter (TTY) number (877) 889-5627. 

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A few words about applicability. The OSHA recordkeeping requirements apply to most transportation employers, though there are exemptions for ... 

Are you subject to OSHA recordkeeping Most companies are, and many companies are fined every year for not keeping the required records. 

You must follow the OSHA recordkeeping mies unless you are specifically exempt. To determine if your company is exempt, refer to 29 CFR 1904.1 and 1904.2. 

Determining exactly which injuries and illnesses to record is the most difficult part of the OSHA recordkeeping requirement. What is considered the workplace What is first aid What is restricted work or a significant injury Fortunately, OSHA has detailed guidance on these and other questions. OSHA guidance can be found in the Reference section of this manual. 

The Occupational Safety and Health (OSH) Act of 1970 requires certain employers to prepare and maintain records of work-related injuries and illnesses. Use these definitions when you classify cases on the Log. OSHAs recordkeeping regulation (see 29 CFR Part 1904) provides more information about the definitions below. 

Within 7 calendar days after you receive information about a case, decide if the case is recordable under the OSHA recordkeeping requirements. 

Under the OSHA Recordkeeping Standard, 29 CFR 1904, covered construction employers are required to prepare and maintain records of serious occupational injuries and illnesses, using the OSHA 300 Log. This information is important for you, your employees, and OSHA in evaluating the safety of jobsites, understanding construction industry hazards, and implementing worker protections to reduce and eliminate hazards. 

Only employers of 11 or more individuals are required to maintain records of occupational injuries and illnesses. OSHA recordkeeping is not required for certain retail trades and some service industries. Even though employers of ten or fewer employees are exempt from recordkeeping, they must still comply with the other OSHA standards, including the requirement to display the OSHA poster. 

Employers with 11 or more employees are subject to OSHA recordkeeping requirements as stated by 29 CFR 1904. They must maintain a record of occupational injuries and illnesses as they occur. Employers with ten or fewer employees are exempt from keeping such records unless selected by the Bureau of Labor Statistics (BLS) to participate in the Annual Survey of Occupational Injuries and Illnesses. Certain low-hazard industries are also exempt. They are, however, subject to the rest of the OSHA regulations applicable to their industry and jobs, and must post the OSHA poster. The purpose of keeping records is to permit the BLS survey material to be compiled, to help define high-hazard industries, and to inform employees of the status of their employer s record (www.OSHA.gov). 

What is the value of records to the employer and to OSHA Recordkeeping requirements by OSHA are heavily emphasized. 

Varions types of reports are necessary to meet OSHA recordkeeping requirements, insnrance carriers, and other government regnlatory agencies. Additionally, some clients may reqnire additional site recordkeeping reqnirements. 

The Occupational Safety and Health Administration (OSHA) requires Afame of Company to record and maintain injury and illness records. These records are used by management to evaluate the effectiveness of this safety and health program. The safety director shall be responsible for following the OSHA recordkeeping regulations listed below ... 

What does this provider know about OSHA recordkeeping requirements ... 

Acquire an understanding of the Occupational Safety and Health Administration (OSHA) recordkeeping process. 

What is the difference between OSHA recordkeeping and the workm compensation process ... 

The OSHA recordkeeping requirements are found in 29 CFR 1904. An interesting issue with the recordkeeping standard is the format in which it is written. Rather than simply presenting factual information as occurs in other standards, OSHA revised this standard to be presented in a question-and-answer format in an effort to make the information more clearly understood. 

What is the applicability of the OSHA recordkeeping regulation to schools ... 

Safety and Health Administration (OSHA) recordkeeping, as well as of best practices in injury management. Combining these issues into an injury management system will create an environment where employees can be returned to work as soon as possible following an injury while also controlling the costs associated with an injury. 

Q. Can you clarify the relationship between the OSHA recordkeeping requirements and the requirements in the Bloodborne Pathogens standard to maintain a sharps injury log ... 

As these paragraphs make clear, OSHA requires employers to follow the physician s or HCP s recommendation when recording a case. For purposes of OSHA recordkeeping, the case met the criteria in 1904.7 at the time of recording because the employee had sustained a work-related injuiy — a bruised knee — involving one or more days away from work. The subsequent MRI results do not change these facts. Accordingly, the MRI results are not a basis to hne out the entry. 

A. OSHA explains that in order to correctly apply the work-related exception 1904. 5(b)(2)(v), the case must meet both of the following conditions. The case must involve first, personal tasks at the establishment and second, must have occurred outside of the employee s assigned working hours. The nature of the activity in which the employee is engaged in at the time of the event or exposure, the degree of employer control over the employee s activity, the preventability of the incident, or the concept of fault do not affect the determination of work-relationship. For purposes of OSHA recordkeeping, the case did not meet the entire criteria under 1904.5(b)(2)(v). 

The instructions that accompany the OSHA recordkeeping forms do include the following Question and Answer When must you post the Summary You must post the Summary only — not the Log — by February 1 of the year following the year covered by the form and keep it posted until April 30 of that year. ... 

OSHA discussed the issue of therapeutic exercise in the preamble to the final rule revising OSHA s injury and illness recordkeeping regulation. OSHA stated that it considers therapeutic exercise as a form of physical therapy and intentionally did not include it on the list of first aid treatments in Section 1904.7(b)(5)(ii). Section 1904. 7(b)(5)(ii)(M) states that physical therapy or chiropractic treatment are considered medical treatment for OSHA recordkeeping purposes and are not considered first aid. Section 1904.7(b)(5)(iii) goes on to state that the treatments included in Section 1904. 7(b)(5)(ii) is a comprehensive list of first aid treatments. Any treatment not included on this list is not considered first aid for OSHA recordkeeping purposes. 

A. Yes. OSHA states that reduction is the care of a disorder not included on the first aid list under 1904.7(b)(5) and therefore it is considered medical treatment for OSHA recordkeeping purposes—even if the injured employee could have performed this procedure by himself or herself... 

Any employer who is required to maintain a log of occupational injuries and illnesses under OSHAs Recordkeeping standard (29 CFR Part 1904) is also required to establish and maintain a sharps injury log for the recording of percutaneous injuries from contaminated sharps. 

Thirdly, OSHA recordkeeping mechanics tend to complicate what is, in essence, really a very simple procedure. Requirements for (i) recording distinctions between injuries and illnesses on the OSHA-200 log, (ii) for placing X s in various columns on the log and (Hi) for carrying forward individual sheet totals of cases and work loss days to aimual totals are fraught with possibilities for errors. 

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