Injuries and Illness

OSHA Recordkeeping Requirements Giving You a Headache?

Because there are so many possible situations involving occupational injuries and illnesses, OSHA’s recordkeeping rules can often be confusing. Today’s Advisor features some frequently asked questions about recordkeeping requirements.

(All questions and answers provided are courtesy of a BLR® special report, Top 100 OSHA Recordkeeping Q&As. Click here to find out how to obtain a copy of the report.)

What are the requirements about saving OSHA injury and illness records?
The OSHA 300 Log, the privacy case list (if one exists), the annual summary, and OSHA 301 Incident Report forms must be saved for 5 years following the end of the calendar year these records cover.

Do I have to update the OSHA 300 Log during the 5-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. You are not required to update the annual summary.
 
When do I have to provide access to the OSHA 300 Log?
You must give the employee or representative requester a copy of the relevant OSHA 300 Log(s) by the end of the next business day.

May I charge for the copies?
No, you may not charge for these copies the first time they are provided. However, if one of the designated persons asks for additional copies, you may assess a reasonable charge for retrieving and copying the records.

May I remove the names of the employees or any other information from the OSHA 300 Log before I give copies to an employee, former employee, or employee representative?
No, you must leave the names on the 300 Log. However, to protect the privacy of injured and ill employees, you may not record the employee’s name on the OSHA 300 Log for certain "privacy concern cases."


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What are the requirements for reporting fatalities and multiple hospitalization incidents to OSHA?
All employers, even in exempt industries, must report to OSHA within 8 hours after the death of any employee or the in-patient hospitalization of three or more employees as a result of a work-related incident. You must orally report the fatality/multiple hospitalization by telephone or in person to the OSHA Area Office that is nearest to the site of the incident. You may also use the OSHA toll-free central telephone number, 1-800-321-OSHA.

Must I record an injury or illness occurring to a contractor’s employee working in my establishment?
It depends on who supervises that employee. If the contractor’s employee is under the day-to-day supervision of the contractor, the contractor is responsible for recording the injury or illness. If you supervise the contractor’s employee’s work on a day-to-day basis, you must record the injury or illness. The same is true for temps.

What if our company has multiple business establishments?
You must keep a separate OSHA 300 Log for each establishment that is expected to be in operation for one year or longer.


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How do I record a work-related injury or illness that results in days
away from work?
You must record the injury or illness on the OSHA 300 Log with a check mark in the space for cases involving days away and an entry of the number of calendar days away from work in the “number of days” column. If the employee is out for an extended period of time, you must enter an estimate of the days that the employee will be away and update the day count when the actual number of days is known.

Note: Begin counting days away on the day after the injury occurred or the illness began. Also count the number of calendar days the employee was unable to work as a result of the injury or illness including weekend days, regardless of whether the employee was scheduled to work on those day(s).

Tomorrow, we’ll present more OSHA recordkeeping FAQs and introduce you to a BLR product that can help you comply with a broad range of OSHA requirements.

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