Setting the Record Straight on OSHA Recordkeeping

If your company has more than 10 employees or isn’t otherwise exempt, you’re probably aware that you have an OSHA deadline coming up.

February 1 is the deadline for submitting your required OSHA recordkeeping forms to report any occupational illnesses or injuries at your establishment.

“Under the OSHA Recordkeeping regulation (29 CFR 1904), covered employers are required to prepare and maintain records of serious occupational injuries and illnesses, using the OSHA 300 Log….All employers covered by the OSH Act must orally report to OSHA 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 within eight (8) hours.”

What is considered “reportable” under the requirement?

• Covered employers must record all work-related fatalities.
• Covered employers must record all work-related injuries and illnesses that result in days away from work, restricted work or transfer to another job, loss of consciousness or medical treatment beyond first aid (see OSHA's definition of first aid below).
• In addition, employers must record significant work-related injuries or illnesses diagnoses by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
• Injuries include cases such as, but not limited to, a cut, fracture, sprain, or amputation.
• Illnesses include both acute and chronic illnesses, such as, but not limited to, a skin disease (i.e. contact dermatitis), respiratory disorder (i.e. occupational asthma, pneumoconiosis), or poisoning (i.e. lead poisoning, solvent intoxication).
• OSHA's definition of work-related injuries, illnesses and fatalities are those in which an event or exposure in the work environment either caused or contributed to the condition. In addition, if an event or exposure in the work environment significantly aggravated a pre-existing injury or illness, this is also considered work-related.

New to the forms? You can do a quick tutorial on how to fill out the required paperwork on the OSHA website.

As mentioned above, OSHA is looking for records of “medical treatment beyond first aid.” “First aid” as the Administration defines it covers:

• Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes)
• Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment)
• Cleaning, flushing or soaking wounds on the surface of the skin
• Using wound coverings such as bandages, Band-Aids, gauze pads, etc.; or using butterfly bandages or Steri-Strips (other wound closing devices such as sutures, staples, etc., are considered medical treatment)
• Using hot or cold therapy
• Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes)
• Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.)
• Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister
• Using eye patches
• Removing foreign bodies from the eye using only irrigation or a cotton swab
• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
• Using finger guards
• Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes)
• Drinking fluids for relief of heat stress

For more information, see OSHA’s helpful FAQs page.

If you are an ASHI or MEDIC First Aid instructor with customers whose businesses require them to submit the OSHA injury logs, Summit Training Source has some resources to help you bring them the training they need:

OSHA Recordkeeping
Complies with OSHA 29 CFR 1904

The Occupational Health and Safety (OSH) Act of 1970 requires employers to prepare and maintain records of occupational injuries and illnesses. It is one of the first documents a compliance officer will ask for. The OSH Act and record keeping regulations in 29 CFR 1904 provide specific recording and reporting requirements. Not complying may result in serious fines.

Our web-based OSHA Recordkeeping program takes a step-by-step approach, instructing your employees how to fill out all the necessary paper work, logs, and forms. Summit's OSHA Record keeping will teach you how to properly record incidents and keep you in compliance, including all up-to-date requirements.

OSHA Recordables (Valley Video)
This exciting and concise video teaches employees the essential aspects of recording workplace illnesses, incidents, and accidents as required by OSHA. Summit's high-quality training program approaches the subject in an easy to understand, common sense manner.

February 1 is right around the corner, so be sure to get your records in order and filed on time!