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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:
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.
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:
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:
To learn more about I2P2 and keep track of legislative progress, visit the MSDSonline Environmental, Health and Safety Blog.
There are three recordkeeping forms employers must contend with, they are:
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.