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Recordkeeping

OSHA's recordkeeping rule requires employers to record and report certain work-related fatalities, injuries and illnesses, and provides employers a system for tracking workplace incidents.

 

Special Update: Proposed Changes to OSHA Recordkeeping and Reporting Requirements for Work-Related Injuries and Illnesses

The Occupational Safety and Health Administration (OSHA) has issued a proposed rule to update and revise two aspects of its recordkeeping and reporting requirements for work-related injuries and illnesses. 

 

Under the new proposed reporting requirements, employers would be required to report to OSHA any work-related fatalities and all in-patient hospitalizations within 8 hours, and work-related amputations within 24 hours. OSHA's current regulation requires an employer to report to OSHA, within 8 hours, all work-related fatalities and in-patient hospitalizations of 3 or more employees. Reporting amputations is not required under the current regulation.

 

OSHA is also proposing to update Appendix A of the recordkeeping rule, which lists industries partially exempt from the requirements to maintain work-related injury or illness logs. These industries received partial exemption because of their relatively low injury and illness rates. The current list of industries is based on the Standard Industrial Classification (SIC) system. The North American Industry Classification System (NAICS) was introduced in 1997 to replace the SIC system for classifying establishments by industry. When OSHA issued the recordkeeping rule in 2001, the agency used the old SIC code system because injury and illness data were not yet available based on the NAICS.

 

To educate employers and employees about the proposed changes, OSHA has updated its Recordkeeping page to include answers to frequently asked questions regarding the proposed rule.

What are the key provisions of OSHA's recordkeeping rule?

The recordkeeping rule:

  • Offers flexibility by letting employers computerize injury and illness records;
  • Updates three recordkeeping forms:
    • OSHA Form 300 (Log of Work-Related Injuries and Illnesses); simplified and reformatted to fit legal size paper. [Download Recordkeeping Forms]
    • OSHA Form 301 (Injury and Illness Incident Report); includes more data about how the injury or illness occurred.
    • OSHA Form 300A (Summary of Work-Related Injuries and Illnesses); separate form created to make it easier to calculate incidence rates;
  • Continues to exempt smaller employers (employers with 10 or fewer employees) from most requirements;
  • Changes the exemptions for employers in service and retail industries;
  • Clarifies the definition of work relationship, limiting the recording of pre-existing cases and adding new exceptions for some categories of injury and illness;
  • Includes new definitions of medical treatment, first aid, and restricted work to simplify recording decisions;
  • Eliminates different criteria for recording work-related injuries and work-related illnesses; one set of criteria will be used for both;
  • Changes the recording of needlestick injuries and tuberculosis;
  • Simplifies the counting of days away from work, restricted days and job transfer;
  • Improves employee involvement and provides employees and their representatives with access to the information; and
  • Protects privacy for injured and ill workers.

Simplified, clearer definitions also make it easier for employers to determine which cases must be recorded. Posting an annual summary of workplace injuries and illnesses for a longer period of time improves employee access to information, and as employees learn how to report workplace injuries and illnesses, their involvement and participation increase.

 

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