For the Record
by Dale Malcolm
An important date is just around the corner. Its the date you need to post your OSHA 300A form for the next three months. If you have or will have had ten or more employees for any part of the current year, you should read this carefully. Failure to comply with this simple task and not keeping accurate records and posting the appropriate form could cost you up to $7,000. Record-keeping violations are consistently in the top ten of fines issued when OSHA pays a visit.
OSHA Recordable and OSHA Reportable are two sides of the same coin. OSHA Reportable is a work-related injury or illness that results in the death of an employee or results in the inpatient hospitalization of three or more employees. This needs to be reported to OSHA within eight hours of learning of the injury or illness. This must be reported orally by phone or in person to the local OSHA area office nearest to the site of the incident. In the event the local office is closed, the OSHA toll-free phone number may be used: 1-800-321-OSHA (1-800-321-6742). The incident also must be recorded on the OSHA 300 Log as any other injury or illness would be. The OSHA 300 Log is the form on which an employer records all injuries or illnesses that occur during a specific calendar year at a specific business location.
A recordable injury or illness is typically, but not limited to, a cut, fracture, sprain or amputation. This is usually associated with a single event or occurrence such as an accident. Illnesses are typically poisoning or skin and respiratory diseases or disorders. These types of illnesses can occur over a longer period of time. A condition such as Carpal Tunnel Syndrome is an illness that occurs from repeated stress and strain on the hands and wrist. This type of illness would be recorded as a musculoskeletal disorder or MSD in the appropriate area of the OSHA 300 Log.
Work-related injuries or illnesses that result in the loss of consciousness, result in lost days or require medical attention beyond first-aid are considered recordable. The term first-aid can apply to the cleaning of an injury, administering tetanus immunizations, applying bandages, issuing nonprescription medications, removing splinters or foreign objects with tweezers or swabs and the use of braces or other immobilizing devices. That could mean that an employee who sought medical attention but only had the wound cleaned and bandaged may not have to have the incident recorded on the OSHA Log. It is important that all employees report injuries or illnesses as soon as possible. All employees should be instructed to notify their supervisors prior to seeking medical attention if the situation allows.
More Record-Keeping Items
Other brief items that apply to record keeping:
Injury or illness incidents must be recorded in the OSHA 300 Log and 301 Incident Report within seven days of the employer being notified of the incident.
Lost days start the day after the incident started and can include weekends and days off.
Records must be kept up to date and retained for five years following the year recorded.
Businesses with multiple locations must maintain records for each location that is in operation for a full year, for each year it is open.
The OSHA 300A Log must be posted no later than February 1st for the preceding year and left posted until April 30th.
The log must be certified by an officer or owner of the company posting the OSHA 300A Log.
The log must be posted even if there are no injuries or illnesses for the year recorded (it does make the form simple to fill out).
The OSHA website, www.osha.gov, has a wealth of information regarding record keeping. It offers were at least record- keeping PowerPoint Presentations that can be downloaded for free, and gets high marks for ease of use and depth of information.
Dale Malcolm is the technical services supervisor for Essex ARG of Dayton, Ohio.
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