Record Keeping Guidelines

7/30/2019 Record Keeping Guidelines

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OSHA Recordkeeping

Guidelines for OccupationalInjuries

and Illnesses


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Provides information to employers & employees on

injuries/illnesses & related hazards in their workplaces

Employers: Management tool for administration of

company safety & health programs

Employees: Raises awareness level

Provides OSHA compliance staff with information tofacilitate inspections

Produces statistical data, thereby measuring magnitude

of nation's injury & illness problem

Why is OSHA

Recordkeeping Important?


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OSHA Recordkeeping

Requirements Division Transfer of recordkeeping function from BLS to

OSHA in 1991; OSH survey functions remain

with BLS Part of OSHA Office of Statistics (created in

1991)

Office of Statistics also includes:

Data Analysis Applied Research, Special Studies &

Publications Statistical Design, Evaluation & Quality

Management


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Duties of the OSHA

Recordkeeping Division

Defining the types of cases entered on the

OSHA Log

Maintaining a consistent recordkeepingsystem for employers covered by the Act

Providing recordkeeping guidance to

employers, employees, and others

Developing regulations and associatedpublications concerning injury and illness

recordkeeping

Support of compliance and litigation activities


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OSHA Recordkeeping -

References

OSH Act of 1970

Section 2 (b)(12) Sections 8(c)(1) & (2) Section 24(a) Section 24(e) - Reports

29 CFR Part 1904 Instructions on the OSHA Forms (200 & 101)

Recordkeeping Guidelines

Letters of Interpretation


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OSH Act

Recordkeeping References

Section 2(b)(12): To assure so far as possible every working man andwoman in the Nation safe and healthful working conditions and to

preserve our human resources ... by providing for appropriate reporting

procedures with respect to occupational safety and health.

Section 8(c)(1): Each employer shall make, keep and preserve, and

make available to the Secretary, such records regarding activities

related to this Act as the Secretary may prescribe ...

Section 8(c)(2): The Secretary ... shall prescribe regulations requiring

employers to maintain accurate records of, and to make periodic

reports on, work-related deaths, injuries and illnesses other than

minor injuries requiring only first aid treatment and which do not

involve medical treatment, loss of consciousness, restriction of work

or motion, or transfer to another job.


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OSH Act - Recordkeeping

References (cont'd)

Section 24(a): The Secretary ... shall develop and

maintain an effective program of collection,

compilation, and analysis of occupational safety andhealth statistics.The Secretary of Labor delegated responsibility for

the injury and illness statistical program to BLS In 1991, the recordkeeping function was

transferred to OSHA (Division of Recordkeeping

Requirements), while BLS retained responsibility

for conducting the Annual Survey Section 24(e): Employers shall file required reports

with the Secretary


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Part 1904 - Recording and Reporting

Occupational Injuries and Illnesses

1904.1 - Purpose and scope 1904.2 - Log and summary of occupational injuries and illnesses 1904.3 - Period covered 1904.4 - Supplementary record 1904.5 - Annual summary 1904.6 - Retention of records 1904.7 - Access to records 1904.8 - Reporting of fatality or multiple hospitalization accidents 1904.9 - Falsification, or failure to keep records or reports 1904.10 - Recordkeeping under approved State plans 1904.11 - Change of ownership

1904.12 - Definitions 1904.13 - Petitions for recordkeeping exceptions 1904.14 - Employees not in fixed establishments 1904.15 - Small employers 1904.16 - Establishments classified in Standard Industrial Classification

Codes (SIC) 52-89, (except 52-54, 70, 75, 76, 79, and 80) 1904.17 - Annual OSHA Injury and Illness Survey of Ten or More Employers


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1904.20 - Description of statistical program1904.21 - Duties of employers

1904.22 - Effect of State plans

STATISTICAL REPORTING OF

OCCUPATIONAL INJURIES AND ILLNESSES

Part 1904 - Recording and

Reporting Occupational Injuries

and Illnesses (cont'd)


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1904.1 - Purpose and Scope

The regulations in this part

implement sections 8(c)(1), (2), 8(g)

(2), and 24 (a) and (e) of the

Occupational Safety and Health Act

of 1970


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1904.2 - Log and Summary of

Occupational Injuries and Illnesses

(a) Each employer shall ... (1) maintain in each establishment a log and summary of all

recordable occupational injuries and illnesses for that

establishment, and (2) enter each recordable injury and illness on the log andsummary as early as practicable but no later than 6 working days

after receiving information that a recordable injury or illness has

occurred (b) The log may be maintained at a place other than the

establishment, or by means of data-processing equipment, or both,

if; (1) at the place where the log is maintained, there is information to

complete the log to a date within 6 working days

(2) at each establishment, the log is current to within 45 calendardays


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1904.4 - Supplementary

Record

In addition to the log, each employer shall

have available for inspection at each

establishment within 6 working days afterreceiving information that a recordable case

has occurred, a supplementary record

(OSHA No. 101) for each occupational injury

or illness for that establishment Workers' compensation or other reports are

acceptable alternatives, if they contain the

information required by OSHA No. 101


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1904.5 - Annual Summary

(a) Each employer shall post an annual

summary of occupational injuries and

illnesses for each establishment

(d)(1) Each employer shall post a copy of the

establishment's summary in each

establishment ... The summary covering the

previous calendar year shall be posted no

later than February 1, and remain in place

until March 1.


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1904.6 - Retention of Records

Records ... shall be retained in each

establishment for 5 years followingthe end of the year to which theyrelate


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1904.7 - Access to Records

(a) Each employer shall provide, upon request, records

provided for in 1904.2, 1904.4, and 1904.5, for

inspection and copying by any representative of the

Secretary of Labor ...

(b)(1) The log and summary of all recordable

occupational injuries and illnesses (OSHA No. 200)

shall, upon request, be made available by the employer

to any employee, former employee, and to their

representatives for examination and copying in a

reasonable manner and at reasonable times


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1904.8 - Reporting of Fatality or

Multiple Hospitalization Accidents

(a) Within 8 hours after the death of any

employee from a work-related incident or the

in-patient hospitalization of 3 or more

employees as a result of a work-relatedincident, the employer of any employees so

affected shall orally report the

fatality/multiple hospitalization by telephone

or in person to the area office of OSHA thatis nearest to the site of the incident, or by

using the toll-free telephone number

The toll-free # is (800) 321-OSHA


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.Falsification, or Failure to Keep

Records or Reports

(a) Section 17(g) of the Act provides that"Whoever knowingly makes any false

statement, representation, or certification inany application, record, report, plan or otherdocument filed or required to be maintainedpursuant to this Act shall, upon conviction,

be punished by a fine of not more than$10,000, or by imprisonment, for not morethan 6 months, or both."


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1904.14 - Employees Not in

Fixed Establishments

Employers of employees engaged in physically dispersedoperations such as construction, installation, repair orservice activities, who do not report to any fixed

establishment on a regular basis, but are subject to commonsupervision, may satisfy the recordkeeping requirements by: (a) Maintaining the required records for each operation orgroup of operations which is subject to commonsupervision in an established central place

(b) Having the address and telephone number of thecentral place available at each worksite, and

(c) Having personnel available at the central place duringnormal business hours to provide information from the

records maintained there by telephone and mail


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1904.15 - Small Employers

An employer who had no more than 10 employees at any

time during the calendar year immediately preceding the

current calendar year need not comply with any of the

recordkeeping requirements, except: (a) Obligation to report under paragraph 1904.8

concerning fatalities or multiple hospitalization

accidents, and (b) Obligation to maintain a log of occupational injuries

and illnesses and to make reports upon being notified

by the Bureau of Labor Statistics that the employer has

been selected to participate in a statistical survey of

occupational injuries and illnesses


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1904.16 - Establishments Classified

in SICs 52-89

(Except 52-54, 70, 75-76, 79-80)

An employer whose establishment is classified in SICs 52-89 (excluding 52-54, 70, 75, 76, 79, and 80) need not

comply, for such establishment, with any of therequirements of this part except: (a) Obligation to report under paragraph 1904.8concerning fatalities or multiple hospitalizationaccidents, and

(b) Obligation to maintain a log of occupational injuriesand illnesses and to make reports upon being notified bythe Bureau of Labor Statistics that the employer hasbeen selected to participate in a statistical survey of

occupational injuries and illnesses


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1904.17 - Annual OSHA Injury and

Illness Survey of 10 or More Employers

(a) Each employer shall, upon receipt of OSHA's Annual Survey

Form, report to OSHA or OSHA's designee the number of workers

it employed and number of hours worked by its employees for

periods designated in the Survey Form and such information as

OSHA may request from records required to be created and

maintained by Part 1904

(b) Survey reports shall be sent to OSHA within 30 calendar days,

or the time stated in the Survey Form, whichever is later

(c) Employers exempted from keeping injury and illness records

shall maintain records and make Survey Reports upon being

notified in writing by OSHA, in advance of the year for which injury

and illness records will be required, that the employer has been

selected to participate in an information collection


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OSHA Forms

OSHA No. 200 - OSHA Log and Summary ofOccupational Injuries and Illnesses: Part IV on

back of form provides instructions forcompletion

OSHA No. 101 - Supplementary Record ofOccupational Injuries and Illnesses


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for Occupational Injuries

and Illnesses

U.S. Department of Labor

Bureau of Labor StatisticsSeptember 1986

The Occupational Safety and Health Act

of 1970 and 29 CFR 1904O.M.B. No. 1220-0029

Effective April 1986

ATTENTION: OSHA RECORDKEEPER

IMPORTANT: DO NOT DISCARD. This bo oklet contains guidelines for

keeping the occupational injury and illness records necessary to fulfill

your recordkeeping obligation under the Occupational Safety and

Health Act of 1970 (29 USC 651) and 29 CFR Part 1904, or equivalent

State law.



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Common Problems with

Recordkeeping Definitions

Definition of work relationship

Definition of illness

Diagnosis of illnesses

Definition of a lost workday

Definition of restricted work activity


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Concept of Work Relationship

If an event or exposure in the work environment caused orcontributed to the onset of symptoms or aggravated existingsymptoms to a point that they meet OSHA recordability criteria, workrelationship is established.

ON PREMISESInjuries and illnesses that result from an event or exposure on the

employer's premises are presumed to be work-related. (Parking lotsand recreational facilities are not considered part of the premises.)

OFF PREMISESInjuries and illnesses that result from an event or exposure off theemployer's premises are work related if the worker was engaged inwork-related activities or are present as a condition of theiremployment."Home away from home" concept: When an employee checks into ahotel or motel, he/she established a "home away form home."Thereafter, his/her activities are evaluated in the same manner as for

non-traveling employees.


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Occupational Illness

Definition: Any abnormal condition ordisorder resulting from a non- instantaneous

event or exposure in the work environment.

Diagnosis: Diagnosis = Recognition

For OSHA recordkeeping purposes, manyillnesses can be diagnosed/ recognized bynon-medical personnel.


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Definition of Lost Workdays

There are two types of lost workdaysDays away from work Days of restricted activity

Lost workday cases are those that involve

days away from work and/or days of

restricted work activity beyond the date of

injury or onset of illness.


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Definition of Restricted

Work ActivityThe employee is physically or mentally unable to

perform all or any part of his or her normalassignment during all or any part of the workday

or shift.

Partial days away from work (e.g., half days)are considered days of restricted workactivity.

Restricted work activity, limited to the day ofinjury or onset of illness, makes a caserecordable.

Transfer to another job almost alwaysinvolves restricted work activity.


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Redesign of OSHA

Recordkeeping System

The redesign of OSHA's recordkeeping

system is currently being undertaken.

This will include revision of: OSHA regulations (29 CFR Part 1904) Recordkeeping Guidelines OSHA Form No. 200 - Log and Summary of

Occupational Injuries and Illnesses OSHA Form No. 101 - Supplementary

Record of Occupational Injury or Illness

G l f th


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Goals of the

Recordkeeping Revisions

Make the system more user friendly

Simplify the system

Improve the utility of the records

Improve employee involvement Meet the intent of the OSH Act

Make the system more compatible with

modern technology

Encourage a more proactive approach toworkplace safety and health

Promote appropriate uses of injury and

illness information


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Proposed Format Changes

Guidelines will be incorporated into theregulations - All information will be in one

place.

Question and answer format will beeliminated - Takes up too much space.

OSHA Log will be letter-size - Will be easierto handle, copy, etc.


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Proposed

Procedural Changes

Computerized recordkeeping enhanced

Employee involvement in recordkeepingprocess improved

Site logs - Develop meaningful information

for multi-employer worksites


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Proposed Definition Changes

Restricted work activity

Medical treatment Case resolution

Work relationship

Injury vs. illness


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Timing of the

Recordkeeping Revisions

Proposal printed in the Federal Register on

February 2, 1996

Comments being reviewed and considered


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OSHA Office of Statistics -

Recordkeeping Division

The address and phone number of OSHA'sRecordkeeping Division are:

Office of StatisticsDivision of Recordkeeping Requirements200 Constitution Avenue, N.W.

Room N-3507Washington, D.C. 20210

(202) 693-1702

Documents

Record Keeping Guidelines