OSHA Recordkeeping

If your company is required to comply with the mandated OSHA standard 29 CFR 1904, then reduce your risk of OSHA imposed citations by maintaining the proper and required written OSHA Recordkeeping documents.

$5,000 to $7,000 is the unadjusted penalty for failure to report to OSHA the death of any employee or the inpatient hospitalization of three or more employees, from a work-related incident.
$7,000 is the maximum penalty for failure to make available the OSHA 301 forms ($1,000 per form), when requested by any employee, former employee, personal representative, or authorized employee representative.


$1,000 is the unadjusted penalty if an employer fails to post the OSHA 300A Summary.

OSHA’s 300 Log

Not all injuries / illnesses are recordable on the log. You must determine if the case is “work related” and meets the criteria for a recordable case.

Examples of injuries / illnesses that occur in the work environment but are not work-related, therefore not recordable:

injury / illness results from voluntary participation in a wellness, fitness or recreational program.

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

injury / illness is solely the result of personal grooming or self medication.

First aid cases are also not recordable, even if the employee has been sent to the hospital. Some examples include:

removing foreign bodies from the eye using only irrigation

administering tetanus immunizations

using hot / cold therapy

visits to the physician solely for observation for counseling

diagnostic procedures such as x rays and blood tests

Some employers record everything “just to be safe”. Why is this a problem? Because too many incidents for your Standard Industry Code (SIC) may trigger an OSHA inspection!


OSHA’s 301 form

Complete an OSHA 301 or an equivalent form for each recordable injury or illness. Many employers use their insurance company’s incident investigation form as an equivalent.

OSHA’s 300 - A form

The annual summary must be completed and certified (signed) by a company executive. You must post a copy of the annual summary in a conspicuous place where notices to employees are customarily posted. The annual summary must be posted no later than February 1st and remain posted until the end of April.

Retention

All forms must be retained for five (5) years following the end of the calendar year that these records cover. So, your 2008 records must be kept until 2013!

Summary

Every year, the U.S. Occupational Safety and Health Administration
sends letters to approximately 80,000 employers across the country
requesting their injury and illness data from the previous year. From this data, OSHA picks 14,000 workplaces with the highest incident rates. Not only are these
workplaces listed on OSHA's website, but from the 14,000 workplaces
listed, 4,500 are then targeted for wall-to-wall inspections.

As we begin a new year I cannot overestimate the importance of accurate recordkeeping. Too many employers either don’t record injuries or record injuries that don't need to be recorded ... skewing their incident rate and making their safety performance appear questionable.

About the Author
Sunny Corona, is Managing Member of Custom Safety Services, LLC and is a Certified Safety Professional with 25 years in the safety field. Custom Safety Services is a safety consulting / training firm specializing in workplace violence/sexual harassment, office /industrial ergonomics, OSHA compliance, Fleet Safety Programs and Return to Work Programs . Contact Sunny@CustomSafetyServices.com or 201-703-6966. http://www.customsafetyservices.com/