Record Keeping and Reporting Requirements

It is a fundamental aspect of a company’s safety program that there is a published methodology for employees to report work- related injuries and illnesses. All injuries/illnesses, no matter how slight, need to be reported in accordance with company policy. Last month’s article discussed the need for accident investigations to identify and cure the root cause of accidents. Today we are going to focus on the next step: meeting OSHA’s requirements for record keeping and reporting.  

Generally, companies with more than 10 employees are required to maintain records of employee injuries/illnesses that occur in the workplace. OSHA logs are comprised of three interrelated forms which are available in Excel format atwww.osha.gov/recordkeeping/RKforms.html.

TheOSHA 301form, entitled the “Injury and Illness Incident Report,” includes detailed information about the employee, the injury/illness and initial treatment.  OSHA regulations allow employees or their representative access to the entire 301 form if it pertains to themselves and the right-hand portion of the forms pertaining to other employees.   

TheOSHA 300log, entitled the “Log of Work-Related Injuries and Illnesses,” contains a listing of all “reportable” injuries/illnesses. This includes work-related injuries/illnesses if they result in the following: death; days away from work; restricted work or transfer to another job; medical treatment beyond first aid; loss of consciousness; or diagnosis of a significant injury/illness. According to OSHA regulations, first aid means the following: using non-prescription medication at non-prescription strength; administering tetanus shots; cleaning wounds; using wound coverings; using hot/cold therapy; using non-rigid means of support; using temporary immobilization devices; drilling a nail or draining a blister; using eye patches; removing foreign bodies from the eye using irrigation or a cotton swab; removing splinters or foreign material by irrigation, tweezers, cotton swabs, etc.; using finger guards; using massages; or drinking fluids for relief of heat stress. 

The 300 log requires computation of lost work days. The calculation is based upon the number of calendar days the employee is away from work with the count of days missed commencing the day after the incident and ending after 180 days have been counted even if the employee has not returned to work. 

TheOSHA 300Alog entitled the “Summary of Work-Related Injuries and Illnesses” is an annual summary of the 300 log. It must be signed by a company executive and posted on the employee bulletin board(s) from February 1 to April 30. The 300A log lists the number of cases, days away from work and injury/illness types and the average number of employees and the total number of hours worked.

Employers are required to call OSHA at 800-321-OSHAwithin eight hoursto report a fatality or work-related injury that results in inpatient hospitalization of three or more employees. Fatal heart attacks occurring in the work environment must be reported. 

Communicating to employees that all injuries/illnesses must be reported when they occur, properly documenting the circumstances surrounding the event, investigating and curing the root cause of the injury/illness and then recording to meet OSHA regulations will result in another step on the path to an effective and compliant safety program, greater productivity, healthy employees working in a safe environment, fewer workers’ compensation claims and a better bottom line. 

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