FAQ S: OSHA Recordkeeping, Reporting and Posting

2850 Clover Street ● Pittsford, New York 14534 Toll Free: 800.462.6435 Tel: 585.381.8070 www.FlandersGroup.com

FAQ’s: OSHA Recordkeeping, Reporting and Posting

Who is required to comply with the OSHA recordkeeping, reporting and posting rule? Every employer who has more than 10 employees, except for certain low-hazard industries which are listed at: http://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html.

**PLEASE NOTE: As of April 1, 2014, OSHA proposed making changes to the list of industries exempt from recordkeeping, reporting and posting.

What forms are required and where can I find them? (1) The OSHA Form 300 is an injury/illness log, with a separate line entry for each recordable injury or illness. The form contains directions on how to determine if an injury or illness meets the criteria for recording.

(2) Each year, employers must post a summary of the OSHA Form 300 on an OSHA Form 300A, which includes the previous year's injuries and illnesses, in the workplace from February through April.

(3) OSHA Form 301 is an individual incident report that provides added detail about each specific recordable injury or illness. A workers’ compensation first report of injury that provides the same details may be substituted for the form.

You can download the required forms in Excel or a PDF from here: http://www.osha.gov/recordkeeping/RKforms.html

Are there other requirements I need to know? Every employer without exception must advise the nearest OSHA office of any accident which results in one or more fatalities or the hospitalization of three or more employees within eight hours of the occurrence of the accident. OSHA often investigates such accidents to determine whether violations of standards contributed to the event.

How long should a client retain OSHA logs and case records? According to OSHA an organization must save the OSHA 300 Log, and Annual Summary, and the OSHA 301 Incident Report forms for five years following the end of the calendar year that these records cover. This requirement exists even if there is a merger or acquisition.

This communication is for informational purposes only and is not legal advice. You are not insured against issues arising out of the use of our consulting, content, or tools and we suggest contacting your attorney for legal guidance. Acceptance of the terms of this policy is a portion of the consideration required for your right to use our information. If you do not accept these terms, please contact us. 2850 Clover Street ● Pittsford, New York 14534 Toll Free: 800.462.6435 Tel: 585.381.8070 www.FlandersGroup.com

Do I have to update the OSHA 300 Log during the five-year storage period? Yes, during the storage period, you must update your stored OSHA 300 Logs to include newly discovered recordable injuries or illnesses and to show any changes that have occurred in the classification of previously recorded injuries and illnesses. If the description or outcome of a case changes, you must remove or line out the original entry and enter the new information.

What are the posting requirements? The "Summary of Work-Related Injuries and Illnesses" (OSHA's Form 300A) for the preceding year is to remain posted from February 1st through April 30th.

What is a recordable case? The basic recordkeeping requirement is to record all work-related injuries and illnesses that result in death, loss of consciousness, medical treatment beyond first aid, days away from work, restriction of work or transfer to another job. The log should include only those cases meeting the recordability criteria. Many workplace incidents may look like recordable injuries, but don’t meet the criteria. Medical treatment is any treatment not included on OSHA’s first aid list.

What is a considered first aid? First Aid includes: • Observation or counseling • Diagnostic procedures, including X-ray, blood tests • Over-the-counter medication • Tetanus shot • Cleaning, flushing, or soaking wounds • Wound coverings, including suture substitutes such as butterfly bandages and Steri-strips • Hot/cold treatment • Non-rigid support such as an Ace bandage. • Temporary immobilization for transport purposes • Drilling of nail to relieve sub-ungula hematoma • Eye patches • Foreign Body removal from eye using only irrigation or swab • Simple skin foreign body removal • Finger guards

This communication is for informational purposes only and is not legal advice. You are not insured against issues arising out of the use of our consulting, content, or tools and we suggest contacting your attorney for legal guidance. Acceptance of the terms of this policy is a portion of the consideration required for your right to use our information. If you do not accept these terms, please contact us. 2850 Clover Street ● Pittsford, New York 14534 Toll Free: 800.462.6435 Tel: 585.381.8070 www.FlandersGroup.com

Can I develop an OSHA log from loss runs? A loss run will not provide all the necessary information in to accurately complete the log.

(1) First Aid for workers comp purposes and First Aid for OSHA are different so there is the potential for under reporting.

(2) Restricted work days are recordable only if it affects one or more of the employee's routine job functions. If the restriction from a physician keeps the employee from performing one or more of his or her routine job functions or from working the full workday the injured or ill employee would otherwise have worked, the employee's work has been restricted and you must record the case. Many employers assume that if someone is back at work in transitional or part-time duty that it is not recordable.

(3) Correctly recording Recovery at Work cases can be challenging. For more information: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27154

What is the best advice The Flanders Group can give about OSHA logs? The OSHA log is a valuable tool to help employers manage workplace safety and health. Keeping an accurate log is only the start of the process.

Share the summary information with your company’s management and the safety committee.

Benchmark your organizational results by comparing the data against the state and national averages for your industry. An incident rate calculator is available at http://data.bls.gov/IIRC/calculate.do.

Use statistics about detailed case characteristics to understand the most common types of injuries and take action to reduce injuries and illness using this valuable data.

Where can I find more information? There are extensive resources located on the OSHA website at: http://www.osha.gov/recordkeeping/index.html

This communication is for informational purposes only and is not legal advice. You are not insured against issues arising out of the use of our consulting, content, or tools and we suggest contacting your attorney for legal guidance. Acceptance of the terms of this policy is a portion of the consideration required for your right to use our information. If you do not accept these terms, please contact us.