- Recognize the purpose of OSHA requirements for work-related injury and illness recordkeeping and fatality reporting by employers.
- Identify the types of organizations that must comply with work-related injury and illness recordkeeping and fatality reporting regulations.
- Identify the criteria for work-related injury and illness.
- Identify the purpose and guidelines for the basic work-related injury and illness record types required under 29CFR Part 1904.
- Recognize OSHA safeguards for privacy in employer recording of work-related illness and injury.
- Recognize reporting requirements for work-related fatalities, severe injuries (amputations, losses of an eye), and hospitalizations.
- Identify employee involvement and rights related to work-related injury and illness reporting and recordkeeping.
- Recognize employer responsibilities for providing work-related injury, illness and fatality records for OSHA inspection and investigation.
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The Occupational Safety & Health Administration (OSHA) requires about 1.5 million employers in the United States to keep records of their employees’ work-related injuries and illnesses.
Safety professionals understand the importance of OSHA injury and illness recordkeeping requirements.
The OSHA website provides employer workplace violation history. Injury and illness recordkeeping is an important part of accountability and should be incorporated into each safety plan; advances in software now make reporting and recordkeeping easier than ever. The regulations in the OSHA Recordkeeping Handbook establish the requirements and criteria for recording and reporting occupational injuries and illnesses.
For employers covered under the Occupational Safety and Health Act of 1970, Part 1904 requires them to keep records of work-related injuries and illnesses and to report fatalities and multiple hospitalizations. It also requires participation in annual surveys. This survey information of workplace injuries helps OSHA establish training initiatives and create new safety regulations.
All employers covered by the Act are regulated by Part 1904 regulations. However, businesses with 10 or fewer employees and businesses with certain industry classifications are partially exempt from keeping OSHA injury and illness records, unless OSHA or the Bureau of Labor Statistics notifies them in writing that they must do so.
All employers covered by OSHA—no matter the number of employees or industry classification—must report to OSHA any workplace incident that results in a fatality or the hospitalization of three or more employees.
General recording criteria refer to injuries or illnesses in the workplace resulting in:
- Days away from work
- Restricted work or transfer to another job
- Medical treatment beyond first aid
- Issuance of prescription medication
- Loss of consciousness
- A significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in any of the other listed criteria
Employers covered under Part 1904 must use three specific OSHA forms for recordable workplace injuries and illnesses: OSHA Form 301 (Injury and Incident Report), OSHA Form 300 (Log of Work-Related Injuries and Illnesses), and OSHA Form 300-A (Summary of Work-Related Injuries and Illnesses).
Here is the typical order of events and the forms that will be used to report an occupational injury or illness:
- When an injury occurs, many employers ask their employees to complete a “first report of injury” form.
- Next, the employee completes OSHA Form 301 (Injury and Incident Report) or a safety director may complete the form for the employee by transferring the information from the “first report of injury” form.
- Now that the injury claim has been established, medical treatment and/or rehabilitation can be provided. Next, the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) is updated to record restricted or lost work days and to document the injury cause.
- Finally, at the end of the calendar year, the OSHA Form 300-A (Summary of Work-Related Injuries and Illnesses) is completed and posted.
A company may keep the records for all establishments at headquarters, or another central location, as long as information about injuries and illnesses can be passed from the establishment to headquarters within seven days of learning of the recordable incident. Analog records should be kept in a fire-safe filing cabinet, and should probably be converted to digital records for ease of access and data management.
Likewise, headquarters must be capable of producing and sending records to the establishment within the timeframes specified for access by government and employee representatives, as well as employees and former employees.
Companies must save all of the forms and the privacy case list—if it exists—for five years following the end of the calendar year they cover. If the business changes ownership, the previous owner must transfer all Part 1904 records to the new owner.
If your company becomes the target of an OSHA inspection or investigation, your employer must provide copies of all Part 1904 records within four business hours, if requested.
Q. What do employers need to know about OSHA’s updated reporting and recordkeeping rule?
A. Federal OSHA has revised its reporting and record keeping (R&R) requirements went into effect January 1, 2015. The rule and its new requirements can be found in the federal standard 29 CFR 1904.39. The change in these requirements will allow OSHA to track and more appropriately respond to serious and fatal incidents including hospitalizations, amputations and the loss of an eye. This data collection will also help OSHA develop prevention programs and modify rules where necessary. The revised rule applies to all industries except where exempt. State-plan-state OSHA programs are afforded time to review the new rule which may delay implementation in those states.
The revised rule now requires reporting of all employers, regardless of size or industry type, for the following circumstances:
- All work-related fatalities within 8 hours.
- All work-related inpatient hospitalizations, all amputations and all losses of an eye within 24 hours.
- You can report to OSHA by:
Only fatalities occurring within 30 days of the work-related incident must be reported to OSHA. Further, for an inpatient hospitalization, amputation or loss of an eye, these incidents must be reported to OSHA only if they occur within 24 hours of the work-related incident.
Employers with ten or fewer employees and certain establishment types, based on their North American Standard Industrial Classification (NAICS) code, are exempt from record keeping requirements. OSHA has prepared a printable fact sheet that includes lists of industry types that were previously exempt and new industries that have been granted exemption. That fact sheet can be found here. For a dialogue of frequently asked questions (FAQ’s) and to monitor implementation of the new rule go to the federal OSHA website: www.osha.gov/recordkeeping2014/
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