OSHA Recordkeeping: Who, How, What, When and Why? Oh My! (Part 1 of 3)
When looking toward the new year, employers often have questions about OSHA injury recordkeeping. I always recommend that they start by pretending to be a newspaper reporter. A reporter cannot begin to do their job without answering five basic questions: who, how, what, when and why. This three-part blog will cover many of the answers to these particularly important questions about OSHA’s recordkeeping requirements.
The “Who”
A look at OSHA regulations 29 CFR 1904.1 and 1904.2 will answer the question of “who” must keep OSHA injury records.
OSHA standard 1904.1 requires recordkeeping for all employers who have more than ten employees at any time during the calendar year. However, having less than ten employees is only a partial exemption. Some smaller businesses may still need to keep records if required by a federal or state agency.
OSHA standard 1904.2 provides an exemption from the recordkeeping requirements to certain types of industries that typically have lower incident rates. This, again, is a “partial exemption” as some business types within the Partially Exempt Industries list might be notified that they must record injuries for a given year.
It is important to note that even if you are a partially exempted establishment, your organization must still report all fatalities, in-patient hospitalizations, amputations, or loss of an eye to OSHA within time frames specified in 29 CFR 1904.39.
The “How”
Once a business establishment has determined its obligation to keep injury records for OSHA, the next step is to become familiar with "how” they must be kept. OSHA has three required forms. Non-exempt businesses must use the OSHA 300 Log to track “recordable” injuries and illnesses that occur during a given calendar year. Separate log entries should be made for each recordable injury or illness as soon as possible after an incident has occurred. Each entry will include the employee’s name, type of injury or illness, the resulting impact on the employee (death, lost time, restricted duty, or job transfer) and the number of days lost, restricted, or transferred.
The OSHA 300A Summary is required to summarize the establishment’s total injuries and/or illnesses for a given calendar year. This form must be completed at the end of the calendar year and posted for all employees to view from February 1st through April 30th of the year following the covered year.
The third and final form is the OSHA 301 Incident Report. OSHA expects employers to complete the 301 or a comparable form to determine the root causes of an incident and possible corrective action.
Knowing the “who” and “how” is a great start. In part 2 of this series, we will take a closer look at “what” information should be included in your OSHA records.
Get more valuable insights! MEMIC policyholders are invited to register for our OSHA Reporting & Recordkeeping webinar on January 31, 2024, at 10 am (EST). Elevate your understanding and ensure compliance with expert guidance. Don't miss out - secure your spot now!
