OSHA Recordkeeping Handbook: Guidelines & Resources for Workplace Safety Compliance

1. Recordkeeping MODULE 8

2. OSHA Information Resources • OSHA Recordkeeping page(cached) • Forms (PDF and XLS) • Also in back of CFR book • Recordkeeping Handbook

3. 29 CFR 1904.0 Purpose • “Require employers to record and report work-related fatalities, injuries and illnesses” • Data used to direct OSHA programs • Data used in employer safety programs • Aggregated in BLS Annual Survey of Occupational Injuries and Illnesses

4. Scope • 1904.1 Exemption for 10 employees • In entire company, at any time during year • Unless OSHA or BLS requires in writing • Must report fatality or 3 hospitalized • 1904.2 Exemption for certain industries • Low hazard industries by SIC code • 1904.3 Records for 1 agency

5. Definitions • 1904.46 • The Act • Establishment • Injury or illness • Physician or Other Licensed Health Care Professional • You

6. 1904.4 Recording Criteria • Record each fatality, injury, or illness: • Work related (1904.5) and • New case (1904.6) and • Meets criteria in 1904.7-12

7. Is the injury or illness work-related? Is the injury or illness a new case? Did the employee experience an injury or illness? YES YES NO UPDATE PREVIOUS RECORD YES Subtitles & Transitions FOR EXAMPLE… Does the injury or illness meet the general criteria or the application to specific cases? YES RECORD THE INJURY OR ILLNESS

8. 1904.5 Work-Relatedness • Basic requirement: (a) • Implementation: (b) • Work environment? • At work but not work-related? • Significantly aggravated? • Pre-existing condition? • Travel status? • Working at home?

9. 1904.6 New Cases • Basic requirement: • No previously recorded similar case, or • Recovered completely. • Implementation: • Recurrence of chronic illness? • First signs/symptoms? • Physician advice?

10. 1904.7 Recording Criteria • Basic requirement: results in • Death • Days away from work • Restricted work or job transfer • Medical treatment beyond first aid • Loss of consciousness • Significant diagnosed injury or illness • Implementation / Questions

11. 1904.8 Needlesticks and Sharps • Record if contaminated with • Blood or • Potentially Infectious Material • Do not record employee’s name

12. 1904.9 Medical Removal • Record medical removals under other OSHA standards • Not if removed voluntarily before overexposure

13. 1904.10 Hearing Loss • Work-related STS in at least 1 ear • Total hearing 25 dB above audiometric zero in same ear(s)

14. 1904.29 Forms • 300 Log, 300-A Summary, 301 Incident Report • Equivalent forms • Privacy concern cases • Voluntary disclosure

15. 1904.30 Multiple Business Establishments • Separate logs if in operation 1 year • May combine short-term on one log • May keep centrally if promptly updated and available • Each employee linked with an establishment • Record at location of occurrence

16. 1904.31 Covered Employees • All on payroll, any status • Non-payroll employees if supervised day to day • Owner/partners not included

17. 1904.32 Annual Summary • Review at end of calendar year • Certify and post annual summary • 300-A or equivalent form

18. 1904.33 Retention and Updating • Save all forms for 5 years • Update for new discoveries or changes • 1904.34: Transfer to new owner

19. 1904.35 Employee Involvement • Inform each employee of how to report • Provide employees limited access to records • 1904.36 Prohibition against discrimination

20. Equivalent systems • 1904.37 State recordkeeping regulations • 1904.38 Variances from recordkeeping rule for alternative system

21. 1904.39 Reporting fatalities and multiple hospitalizations • Orally report within 8 hours of death or hospitalization of 3 employees

22. Providing records to government • 1904.40 Provide within 4 hours or authorized government representative request • 1904.41 Return annual survey form if received • 1904.42 Return BLS survey form if received