OSHA Recordkeeping

Employment Relations Division

Occupational Safety and Health Bureau

• “Just because the numbers are good doesn’t 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 aren’t dedicated to improving processes, you’re doing one of the other two.”o Dr. W. Edwards Deming Author and Consultant.

• Identify the OSHA requirements for recordkeeping, posting and reporting

• Acquire an understanding of the OSHA 300, 300A and 301.

• 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

• The system is simpler and provides better resources than the old system

• Greater employer flexibility determining recordability

• Some aspects reduce ORIs, some increase ORI’s

• Day counts are not comparable to previous years due to changes

• 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

• 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

• 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

• 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

• 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

• 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 year’s log

• The OSHA 301 “Injury and Illness Incident Record” provides detailed information about: o the affected worker, o the injury or illness, o the workplace factors associated with the accident, o 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.

• 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.

• Record every fatality, injury or illness that meets these criteria:o Work-related,o A new case, o Meets one of the general or specific recording criteria

found in the regulation. • The same requirements now apply to both

injuries and illnesses.

• 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):o death o loss of consciousnesso a day or days away from work, restricted work or job

transfero medical treatment or a change in the course of

medical treatment.

• 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

• Injuries and illnesses that occur while an employee is working at home are work-related if they:o occur while the employee is performing work for pay

or compensation in the home, and o they are directly related to the performance of work

rather than the general home environment

• A case is new if:o The employee has not previously experienced a

recordable injury or illness of the same type that affects the same part of the body; or

o 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

o If there is a medical opinion regarding resolution of a case, the employer must follow that opinion

• Cases occurring on the work premises are presumed to be work-related except when they involve:o Eating, drinking or preparing food or drinko Common colds and flu o Voluntary participation in wellness program, medical, fitness, or

recreational activity o Mental illness (unless employee voluntarily provides an opinion from

a licensed health care professional stating condition is work related)o Employee is at work as a member of the general public rather than

as an employee. o Symptoms surface at work but result solely from a non-work-related

event or exposure. o Doing personal tasks at work outside normal work hours. o Grooming, self-medication, or intentionally self-inflicted. o A motor vehicle accident on a company parking lot or company

access road while commuting to or from work

• 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

• 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

• Restricted work activity occurs when:o 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

o An employee is kept from working a full workday; or

o A PLHCP recommends either of the above

• Job Transfero An injured or ill employee is assigned to a job other

than his or her regular job for part of the dayo 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

• Medical treatment is the management and care of a patient to combat disease or disorder

• It does not include:o Visits to a PLHCP solely for observation or

counselingo Diagnostic procedureso First aid

• 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

• 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

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

• 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)

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 HzBoth allow age adjustments according to the Hearing Conservation Standard

• 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

• 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

• 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

• 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

• 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:o Intimate body part or reproductive system o Resulting from a sexual assault o Mental illness o Communicable diseases (HIV, hepatitis, tuberculosis) o Contaminated Needlestick and sharps injuries o Other merited employee requests

• 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

• 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:o Employers must report fatal heart attacks that occur at worko Employers do not have to report motor vehicle accidents

that occur in a public street o 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.

• Days Away From Work• Days of Restricted Work Activity• Job Transfer• Formula:

o Number of entries in Column H x 200,000/Number of hrs worked by all employees = DART incidence rate

• Incidence rate for all recordable cases of injuries and illnesses

• Formula:o Total number of injuries & illnesses x

200,000/Number or hrs worked by all employees = Total recordable case rate

• Information is constantly changing – bookmark and refer to this webpage:

www.osha.gov