OSHA Injury/Illness Reporting and Recordkeeping Requirements

It has recently come to our attention that there is some confusion among our member agencies about the services and the need for them to comply with the injury/illness reporting and recordkeeping requirements of the Occupational Safety and Health Administration (OSHA).

The following summary should explain these recordkeeping requirements.

• Services relating to only adult day care and/or activity centers for the elderly or handicapped are exempted from these recordkeeping requirements Records of the occupational injuries and illnesses that occur among your employees for these services do not have to be maintained.
  
• Services, such as residential care, job training and vocational rehabilitation are not covered by any of the partial exemptions afforded by OSHA to certain businesses. Therefore, if your agency provides these services, you are required by law to comply with these recordkeeping regulations and must keep records of the occupational injuries and illnesses that occur among your employees providing these services. These records must be maintained for 5 calendar years. In addition employers are now required to post the annual summary for each year from February 1st to April 30th.

Information on these recordkeeping requirements and the newly revised OSHA Form 300, Log of Work-Related Injuries and Illnesses is available on OSHA's website at http://www.osha-slc.gov/recordkeeping/new-osha300form1-1-04.pdf

The forms are required for employers to use in recording injuries and illnesses and employers must begin to use the new OSHA Form on January 1, 2004. They have changed in vary important ways. Most significant among the changes is the addition of an occupational hearing loss column. Other changes include:

• the "days away from work" column now comes before the days "on job transfer or restriction;"
• clearer formulas for calculating incidence rates
• new recording criteria for occupational hearing loss is in the "Overview" section;
• a more prominent column heading "Classify the Case" to make it clear that employers should mark only one selection among the four columns offered.

These changes were made in response to public suggestions on making the forms easier to use. Injuries and illnesses for years prior to 2004 should continue to be recorded on the appropriate form for that year (i.e., 2003 and 2002 injuries and illnesses should be recorded on the forms for those years). The forms for 2003 and 2002 will continue to be available at: http://www.osha.gov/recordkeeping/OSHArecordkeepingforms.pdf

Employers should use the old OSHA 300A Summary Form (without the hearing loss column) to post as required in February 2004. The new 300A form that includes the hearing loss column should be used to post in February 2005.

Hard copies of the new OSHA 300 form will be available beginning in November 2003, and can be obtained by calling 1-800-321-OSHA.

With regard to complying with OSHA’s reporting requirements, be advised that all HSBC-insured agencies are subject to the following reporting rule:

• Within eight (8) hours after the death of any employee from a work-related incident 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 Area Office of the Occupational Safety and Health Administration (OSHA), U.S. Department of Labor, that is nearest to the site of the incident. You may also use the OSHA toll-free central telephone number, 1-800-321-OSHA (1-800-321-6742).

If you have any questions regarding compliance with these reporting and recordkeeping requirements, please use our "Ask the Safety Expert" service. Answers to your question will be promptly provided by an HSBC Safety Associate.