OSHA Recordkeeping
Don't Procrastinate
“Tomorrow is often the busiest day of the week.” ~Spanish Proverb
These words seem appropriate as we remind you that we are less than six months away from your mandatory posting of the OSHA Form 300A, Summary of Work-Related Injuries and Illnesses, which must be completed and posted by February 1st 2009. DON’T PROSCRASTINATE keeping your log up to date or you may find yourself out of compliance and overwhelmed on January 31st!
Here are a few tips and facts about OSHA Recordkeeping from your safety partners at Hellman & Associates. Please contact us if you need safety support or have questions about your recordkeeping requirements.
Electronic versions of the OSHA 300 and 300A forms can be very helpful in keeping your records up to date. Please go to the OSHA website to get your forms. OSHA only requires that you record OSHA recordable instances on the OSHA 300 and 300A forms. Do not record every workers compensation injury on your OSHA forms; the OSHA standards and the workers compensation standards are very different. Only workplace injuries and illnesses that fall into specific categories are recordable:
Death: Subpart C, 29 CFR 1904.7(b)(2)
Days away from work: Subpart C, 29 CFR 1904.7(b)(3)
Restricted work / transfer: Subpart C, 29 CFR 1904.7(b)(4)
Medical Treatment: Subpart C, 29 CFR 1904.7(b)(5)
Loss of Consciousness: Subpart C, 29 CFR 1904.7(b)(6)
Other significant injury or illness: Subpart C, 29 CFR 1904.7(b)(7)
Needlesticks and sharps: Subpart C, 29 CFR 1904.8
Medical Removal: Subpart C, 29 CFR 1904.9
Tuberculosis: Subpart C, 29 CFR 1904.11
Ensure you are recording data on the form correctly. The information below indicates which sections of the rule address each topic:
Determination of work-relatedness – See §1904.5
Determination of a new case – See §1904.6
General recording criteria – See §1904.7
Additional criteria (Needlestick and sharps injury cases, tuberculosis cases, hearing loss cases, medical removal cases and musculoskeletal disorder cases) – See §1904.8 through §1904.12.
Data on the OSHA 300 form is used by OSHA inspectors during inspections to help direct their efforts to the hazards that are injuring workers. Additionally, you may currently be required to submit your OSHA 300 logs to the Bureau of Labor Statistics for the OSHA Data Initiative (ODI) to help direct its programs and measure its own performance. The OSHA 300 log should be used by you and your company to evaluate your safety and health program, define areas for improvement, and for tracking progress in solving those problems. The decision tree for recording work-related injuries and illnesses below shows the steps involved in making this determination.
Please contact Hellman & Associates for any support with your OSHA 300 logs and how to effectively use this tool for improving your safety and health performance.
Hellman & Associates, Inc. 2221 East Street, Unit #202
Golden, CO 80401
303-384-9828
rhellman@ehscompliance.com
www.ehscompliance.com
301 So. Elm Street, Suite 524
Greensboro, NC 27401
336-282-6440
cpope@ehscompliance.com
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