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What is OSHA's Recordkeeping Standard?
In 1970, the newly created OSH Act compelled employers to prepare and maintain records related to occupational injuries and illnesses. Officially called OSHA’s Recordkeeping Standard, you might know it by one of these other names, The Recordkeeping Rule, 29 CFR 1904 or the Incident Management Reg.
In 2001 OSHA updated the standard to simplify the reporting rules and forms and bring about greater accountability. While some businesses are partially exempt from the standard (e.g., those with 10 or less employees), there are three key forms most employers must contend with:
- Form 301 captures detailed information about workplace injuries and illnesses, such as descriptive explanations of the incident and the physician or health care professional’s contact information. Form 301 acts as your first injury report form.
- Form 300 acts as your LOG of incidents. It includes columns to classify work-related injuries and illnesses and notes the extent and severity of those items.
- Form 300A is essentially a numerical summary of incidents for a particular location. Employers must post this form annually from Feb 1- April 30 in a location clearly visible to employees and new applicants.
One of the trickiest aspects of complying with the OSHA Recordkeeping Standard is knowing what injuries and illnesses are recordable. A decision tree can help, but workplace incidents are rarely black and white. This is one area where a good electronic system can provide great benefit.
These days OSHA is moving beyond injury and illness reporting and seeking a more proactive approach to addressing hazards. It’s also investigating the use of technology to get better information – faster. To that end, electronic filing of injury and illness recordkeeping data is on OSHA’s radar and could lead to the required annual submission of injury and illness data from all non-exempt businesses.
Dangers of Non-
Compliance
Information collected by OSHA and the Bureau of Labor Statistics (BLS) is used by OSHA for targeting inspections, measuring performance, developing standards, allocating resources, “low-hazard" industry exemptions and determining Voluntary Protection Program (VPP) eligibility.
BLS has reported that there are 4 to 6 thousand workplace fatalities every year and between 3.9 and 4.5 million nonfatal injuries and illnesses each year. And those are the just the recorded numbers. The penalty for employers and businesses not meeting the recordkeeping challenge can be steep and include:
- Fines (upwards of $10,000 per violation)
- Potential Risk and Liability
- Downtime and Internal Disruption
- Negative Press
- Damage to Corporate Image
- Lost Revenues
I2P2 on the Horizon
A current priority for OSHA is passage of the Injury and Illness Protection Program (I2P2) which will compel companies to take a proactive approach to injury and illnesses. Instead of simply reporting on workplace incidents and fixing problems after the fact, I2P2 would force companies to have a system of identifying and fixing hazards before injuries or illnesses occur. Based on the successful Voluntary Protection Program (VPP), I2P2 call on businesses to:
- 'Find and fix' workplace hazards
- Engage management and employees in companywide injury and illness prevention program
- Employ hazard prevention analysis and controls
To learn more about I2P2 and keep track of legislative progress, visit the MSDSonline Environmental, Health and Safety Blog.
Zero-Incident Resource Center
- Recordkeeping Forms
- OSHA Recordkeeping Resources
- State OSHA Recordkeeping Info
There are three recordkeeping forms employers must contend with, they are:
Form 300 — Log of Work-Related Injuries and Illnesses
- Acts as your log that an incident occurred
- Includes columns to classify work-related injuries and illnesses
- Notes the extent and severity of injuries and illnesses
- Privacy purposes, don’t have to include employee name for certain cases
- This form is for classifying work-related injuries and illnesses and for identifying their severity.
- While this form does have a field for noting employee names, for privacy purposes, you are not permitted to include names for certain types of injuries or illnesses.
Form 301 — Injuries and Illnesses Incident Report
- Captures detailed information about the incident
-
Includes details that the 300 Form (or equivalent) does not
- Physician Contact Information
- Descriptive explanations of the incident
- You have 7 days after being informed that an injury or illness occurred to fill out this form or an equivalent
- You must keep this form on file for 5 yrs following the year for which it pertains
Form 300A — Summary of Work-Related Injuries and Illnesses
- Must be posted annually from Feb 1 - April 30 in location clearly visible to employees and applicants for employment
- Numerical summary of cases within each category (deaths, days away from work, etc.)
- Total days away from work or days of job transfer or restriction
- Total # of Injury and Illness types (poisonings, hearing loss, etc.)
Facilities must have separate forms for each facility (unless it is open for less than 1 year) and must retain copies that are accessible for 5 years following the year of the recorded incident(s). Be sure to use a decision tree for each incident to make sure it is a recordable incident.