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OSHA Recordkeeping

2

OSHA Recordkeeping

Purpose: to require employers to record

and report work related fatalities,

injuries, and illnesses.

Exemptions: employers with fewer than

10 employees for the entire year;

business establishments classified as

low hazard retail, service, finance,

insurance, or real estate.

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Low Hazard Exemptions

SIC codes specifically listed in Appendix

A of the Recording and Reporting

Section of 29 CFR 1904

Includes hardware stores, meat and fish

markets, candy stores, new and used

car stores, gasoline service stations,

barber-beauty shops, insurance

carriers, others listed.

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Recording Criteria

1. Work related

2. is a new case

3. meets one or more specifics of

general recording criteria

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Work Relatedness

If an event or exposure in the work

environment either caused or contributed to

the resulting condition or significantly

aggravated a pre-existing condition.

The work environment includes areas where

one or more employees are working or

present as a condition of their employment

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Not Work Related

If the employee was present in the work

environment as a member of the general

public

Surfaces at work but resulted from a non

work related event or exposure

Results from a voluntary participation in a

wellness program, blood donation, exercise

class, flu shot, or other recreational activity

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Not Work Related

The injury or illness is solely the result of an employee preparing food or drink or eating/drinking for personal consumption

Results from performing personal tasks outside of work hours

Self inflicted or a personal grooming activity

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Not Work Related

Motor vehicle accident while commuting

to or from work

Common cold or flu

Mental Illness

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New Case

Is a new case if;

1. The employee has not previously experienced a recorded injury or illnes of the same type, or same part of the body; or

2. The employee had recovered completely and the injury caused the symptoms to reappear.

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General recording Criteria

Results in;

1. Death;

2. Days away from work;

3. Restricted work or job transfer;

4. Medical Treatment beyond first aid;

5. Loss of consciousness

6. A significant injury or illness diagnosed by a

physician

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Death

Notify OSHA within 8 hours of

occurrence

* Even if you are unsure if it is work

related- example- heart attack

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Days Away/Restricted/Transfer

Days Away- do not count the day of the

injury. Count calendar days from date

of injury to include RDO’s. If the number

is not known enter an estimated number

and correct later

Cap the number of days at 180

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Restricted/Transfer

Restricted if you keep the employee from performing one or more routine job functions or from working the full day

Or if a physician recommends the above

Routine functions are those that the employee performs at least once a week.

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Beyond First Aid

If the case involved medical treatment it

must be recorded- Medical Treatment is

above first aid; but is not a visit to a

physician or OHCP solely for

observation, conduct of diagnostic

procedures such as x-rays, blood tests,

or prescribed meds for diagnostic

purposes

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First Aid

Using non-prescription meds at non-prescription levels

Tetanus shots- purely preventive in nature

Cleaning, flushing, soaking

Wound coverings such as band-aids, butterfly strips, gauze.

sutures and staples are considered Med Treatment/wound closing devices

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First Aid

Hot or Cold Therapy

Using non-rigid means of support (wraps)

Using temporary immobilizing devices

Eye patches

Drilling fingernails, draining blisters

Removing foreign objects from an eye with swabs, or irrigation

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First Aid

Removing splinters by simple means

Using finger guards

Using massages ( Pt or chiropractic

visits are medical treatment)

Drinking fluids for relief of heat stress

* Procedure determines recording criteria,

not the status of the treating party

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Types of Cases

Sharps injuries- do not enter employees

name- denote case as a “S” or sharps case

Privacy Case- employee requests privacy or

injury is to intimate part of the body- do not

enter name- denote as “P”

Exposure cases-denote as an “E”-must keep

for 30 years after retirement/or separation

19 OSHA Form 300

20 OSHA Form 301

21

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Recording Criteria Decision Tree

Did the employee experience an

injury or illness?

Is the injury

or illness a new case?

Is the injury or

illness work-related?

Does the injury or illness meet the general recording criteria

or the application to specific cases?

Update the previously

recorded injury or illness

entry if necessary.

NO

YES

YES

YES

YES

Record the

injury or illness

Do not record the

injury or illness

NO

NO

NO

1904.4

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Musculoskeletal Disorders

Applies the same recording criteria to

musculoskeletal disorders (MSDs) as to

all other injuries and illnesses

Employer retains flexibility to determine

whether an event or exposure in the

work environment caused or contributed

to the MSD

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Tuberculosis & Medical

Removal Includes separate provisions describing the recording criteria for cases involving the work-related transmission of tuberculosis

Requires employers to record cases of medical removal under OSHA standards

1904.11 & 1904.9

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Employee Involvement

Requires employers to establish a procedure

for employees to report injuries and illnesses

and tell their employees how to report

Employers are prohibited from discriminating

against employees who do report

Employee representatives will now have

access to those parts of the OSHA 301 form

relevant to workplace safety and health

1904.35 & 36

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Employee Privacy Prohibits employers from entering an individual’s name on Form 300 for certain types of injuries/illnesses

Provides employers the right not to describe the nature of sensitive injuries where the employee’s identity would be known

Gives employee representatives access only to the portion of Form 301 which contains no personal information

Requires employers to remove employees’ names before providing the data to persons not provided access rights under the rule

1904.29(b)

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Annual Summary

Requires the annual

summary to be

posted for three

months instead of

one

Requires certification

of the summary by a

company executive

1904.32

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Injury Rate

Must take the number of recorded injuries and times by 200,000

Divide by the number of actual hours worked for that year.

Incidents total x 200,000 / actual hours

* 200,000 is number of hours worked for 100 employees 50 weeks per year