OSHA revises recordkeeping regulations

New rules for how employers keep track of work-related injuries and illnesses go into effect January 1, 2002. OSHA issued the long-awaited update of recordkeeping practices on January 19, 2001.

About 1.3 million workplaces will be required to follow the new recordkeeping procedures. Employers with 10 or fewer employees will continue to be exempt from most requirements, as will a number of industries classified as low-hazard sectors. (All employers covered by OSHA must continue to report any workplace incident resulting in a fatality or the hospitalization of three or more employees.)

During the current year of 2001 employers must follow the requirements of OSHA’s original recordkeeping rule.

The new rules update three recordkeeping forms: OSHA Form 300 (Log of Work-Related Injuries and Illnesses); OSHA Form 301 (Injury and Illness Incident Report); and OSHA Form 300A (Summary of Work-Related Injuries and Illnesses).

Here’s what you need to know. The new recordkeeping rule:

Eliminates different criteria for recording work-related injuries and illnesses — one set of criteria will be used for both.
Requires your records to include any work-related injury or illness resulting in one of 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 by a physician or other licensed health care professional;
Includes new definitions of medical treatment, first aid, and restricted work to simplify your recording decisions.
Requires a significant degree of aggravation before a pre-existing injury or illness becomes recordable.
Adds additional exemptions to the definition of work-relatedness to limiting recording cases involving eating and drinking of food and beverages, common colds and flu, blood donations, exercise programs, and mental illness.
Clarifies how to record “light duty” or restricted work cases. You’ll now record cases when the injured or ill employee is restricted from their “normal duties”, which are defined as work activities the employee regularly performs at least once weekly.
Eliminates the term “lost workdays” and focuses on days away or days restricted or transferred. Also, new rules for counting these days rely on calendar days rather than workdays.
You’ll be required to record standard threshold shifts in employee hearing. The new OSHA 300 Form has a separate column to capture statistics on hearing loss.
Forms also include columns dedicated to musculoskeletal disorder cases. You’ll use the same recording criteria for MSD cases as for all other injuries or illnesses.
All needlestick and sharps injuries involving contamination by another person’s blood or other bodily fluids must be recorded.
You must set up a procedure for your employees to report injuries and illnesses, and you must tell your employees how to report. You are prohibited from discriminating in any way against employees who do report. (This could have ramifications regarding how safety incentive programs based on zero injuries are used.)
For the first time, employee representatives have access to parts of the OSHA 301 Form that are relevant to the employees they represent.
Your annual summary of injuries and illnesses will have to be posted for three months instead of one.
Your summary must be certified by a company executive.