Brief Recordkeeping Overview Presentation Script
Slide 1 - OSHA Recordkeeping
This program discusses the provisions of OSHA's Recordkeeping Rule and incorporates the following changes effective January 1, 2004:
- Section 1904.12, Recording criteria for cases involving work-related musculoskeletal disorders, is deleted.
- The requirement in section 1904.29(b)(7)(vi) stating that MSD injuries and illnesses are not to be considered privacy concern cases is deleted.
- A column for recording hearing loss cases has been added to the OSHA Form 300 log.
- An entry for hearing loss cases has been added to the OSHA Form 300A Summary.[Employers should use the old 300A Summary Form (without the hearing loss entry) to post as required in February 2004. The new 300A form that includes the hearing loss entry should be used to post in February 2005.]
Presenter's Note: Prior to the presentation, it is suggested that presenters review the latest information on the recordkeeping rule. In addition, presenters should print copies of OSHA's main Recordkeeping page as a handout to inform audience members of the latest information available on the website.
OSHA has a new, improved set of rules for recordkeeping. These
new requirements - Part 1904 of 29CFR - took effect January 1, 2002.
Injury and illness records are critical indicators - both for
employers and for OSHA. They tell us how we're doing in our efforts to keep
workers safe. They pinpoint weaknesses - breakdowns in machinery, inadequate
personal protective equipment, failures in communication, insufficient
training. When a worker gets sick or hurt, something has gone wrong. And
employers need to look at these cases to see if they can take action to prevent
But there is also great value in reviewing the records as a
whole to identify patterns and trends. What's happening in specific departments
and across the facility? How does your injury and illness experience stack up
against others in your industry? Is it clear that your employees understand the
need to wear protective equipment and follow safety rules? Asking these
questions - and taking action in response to the answers - can prevent future
injuries and illnesses and improve a company's bottom line. Whenever OSHA
visits a workplace, injury and illness records are the first thing the
inspectors want to see. These records give us a starting point to identify
where problems may lie. Of course, if a company has been tracking its
experience and addressing these issues, what we may find is that the site has
corrected hazards and resolved concerns.
In addition, each year about 80,000 sites in high-hazard
industries are asked to send injury and illness data directly to OSHA. This
gives us an opportunity to track data directly and identify individual sites
that need to improve.
Records are important beyond individual establishments. We
need to know how we're doing collectively - the entire U.S. workforce. We need
to find out where the problems are so we can work to address them. The Bureau
of Labor Statistics surveys about 200,000 employers - of all sizes and in all
industries - to develop the national estimate of workplace injuries and
illnesses issued every December.
Slide 2 - Recordkeeping History
- OSHA has required employers to keep injury and illness records
since 1971, the year the agency was formed. This is the first major effort to
improve the system established 30 years ago. Under the new rule, about 1.4
million sites will maintain injury and illness records.
- The final rule was published on January 19, 2001.
- The recordkeeping rule went into effect as scheduled on
January 1, 2002, with two exceptions: requirements for recording hearing loss
and defining musculoskeletal disorders (MSDs).
- On July 1, 2002, OSHA issued a final rule that revised the
criteria for recording work-related hearing loss. Beginning January 1, 2003,
you record a case when a hearing test reveals that an employee has experienced
a work-related Standard Threshold Shift (STS) in one or both ears and the
employee's total hearing level is 25 dB or more above audiometric zero in the
same ear as the STS. Forms revised for use January 1, 2004 include a hearing
- Also on July 1, 2002, the Agency asked for public comment on a
delay for the definition of musculoskeletal disorders (MSDs) and whether to
include a separate column for MSDs on the OSHA 300 Log. Based on comments
received, OSHA has decided not to include the separate MSD column and ¶
1904.12 has been deleted. The deletion has no effect on an employer's
obligation to record all cases meeting the requirements of ¶
1904.4-1904.7. If a musculoskeletal disorder is work-related, and is a new
case, and meets one or more of the general recording criteria, it must be
- As noted earlier in this presentation, employers must begin to use the new OSHA
Form 300 on January 1, 2004. The new 300A form that includes the hearing loss
column should be used to post in February, 2005.
Slide 3 - Recordkeeping Goals
In revising the rule, OSHA had several goals: improve the
data, make recordkeeping simpler for employers, maximize the use of computers
and technology, improve employee involvement and protect the privacy of the
injured or ill worker.
Slide 4 - Am I Covered?
Presenter's Note: Provide handout on Partially Exempt Industries.
When it comes to OSHA recordkeeping, the first question an
employer needs to ask is: Am I covered? Every employer - regardless of size or
industry - must orally report any incident that involves the death of a worker
and/or the hospitalization of three or more workers. You must call your local
OSHA office or 1-800-321-OSHA within eight hours. You don't have to report most
highway or commercial carrier accidents, but you must report fatal heart
attacks that occur at work. [§1904.39]
If you have 10 or fewer workers, you normally do not need to
keep injury and illness records. Remember to include temporary employees under
your direct supervision in that count. And if you're in one of the exempt
low-hazard industries, you don't have to keep records unless OSHA or BLS asks
you to participate in their annual surveys. [§1904.1 &
Slide 5 - What is Recordable?
Second, you need to know what to count. The injuries and
illnesses you record must be new cases that are work-related. That includes
pre-existing conditions that are significantly aggravated by workplace events
or exposures. [§1904.4 & §1904.5]
What do you actually record? Injuries and illnesses that
- Days away from work
- Restricted work or transfer to another
- Medical treatment beyond first aid
- Loss of consciousness
- Significant injury or illness diagnosed by a physician or other licensed healthcare professional. [§1904.7]
We've also got a new list of exceptions - problems not
considered work-related. The rule makes it clear that employers don't have to
record cases involving eating and drinking food and beverages, common colds and
flu, blood donations, and exercise programs. In addition, mental illness will
not be recorded unless the employee voluntarily provides the employer with an
opinion from an appropriate licensed healthcare professional stating that the
employee's mental illness is work-related. But some injuries to employees doing
work at home or while traveling on business are counted.
Slide 6 - Other New Elements
What you don't record are injuries or illnesses treated
through first aid - such as taking aspirin, getting a tetanus shot, applying a
butterfly bandage, draining a blister, wearing a finger guard, etc. For
recordkeeping purposes, first aid cases are not recordable. The rule provides
an absolute list of what is first aid. If a treatment is NOT on the list, it
MUST be considered medical treatment. [§1904.7(b)(5)(ii)]
We're also making it simple when it comes to counting days
away from work or days of restricted work activity - just count calendar days.
This will make the counts more consistent and make the actual length of an
injury or illness clear. [§1904.7(b)(3)]
Employers need to record all injuries from needles and sharps
that are contaminated by another person's blood or other potentially infectious
material, not just those that lead to illness. They'll also record a case for
any worker removed from work under the provisions of an OSHA standard - such as
lead. The new rule also makes it clear that work-related cases of tuberculosis
should be recorded. [§1904.8; §1904.9; §1904.11]
Slide 7 - Forms
Let's talk about the new forms. There are three: the 300 log,
which replaces form 200; 301, which replaces 101; and 300A, a separate form to
use to display the annual summary. [§1904.29]
The 300 log is a listing of all the injuries and illnesses at
your site. You can maintain it on a computer or at another location as long as
you can produce a copy at the workplace whenever it's needed. You have seven
calendar days to fill in the form once you learn of a case.
The 301 form is the individual record of a work-related injury
or illness. You'll fill out a new form for each case - again within seven
calendar days. You can use an equivalent form if you prefer.
Form 300A is the summary of work-related injuries and
illnesses. This is the one you post every year. The new rule requires a
three-month posting - February 1 to April 30. The summary must be certified by
a company executive - the owner, an officer of the corporation, the highest
ranking company official working at that site, or his or her supervisor. Top
management needs to be aware of the injury and illness experience of the site
and verify that the records are accurate. [§1904.32]
With the new forms come new privacy protections for workers.
You won't enter the name of workers for sensitive cases such as injuries
or illnesses involving an intimate body part or the reproductive system, sexual
assault, HIV or hepatitis infection, tuberculosis, mental illness or other
similar cases. You do need to keep a separate, confidential identity list for
these cases. Regardless of the injury or illness, if you share your records
with anyone not authorized by the rule to see them, you must remove employee
names before doing so. [§1904.29]
OSHA recordkeeping forms must be kept for five years following
the year they cover. During that time you need to update the OSHA 300 form to
include newly discovered cases or to show changes in old cases. You do not have
to update the 301 and 300A forms. Be sure to transfer the recordkeeping forms
if you sell your business. [§1904.33 & §1904.34]
There are some additional considerations. Temporary workers
and contract workers, for example. You must record their injuries and illnesses
the same as any other worker on your payroll, if you are supervising their
Slide 8 - Employee Involvement
To be sure your records are complete, you must tell each
employee how to report a work-related injury or illness. This means setting up
a reporting system and informing each worker of the system.
Workers and their representatives have a right to review the
300 log - no later than the end of the next business day - with all the names
on it, (except, of course, the names for the privacy concern cases). Workers,
former workers or personal representatives must be able to get copies of Form
301 covering their own injuries or illnesses by the end of the next business
day. Authorized representatives can have access to just the "information about
the case" section of any or all 301 forms within seven calendar days. You must
provide records within four business hours to authorized government
representatives such as OSHA inspectors or NIOSH investigators. [§1904.35
Slide 9 - State Programs
States that operate their own job safety and health programs
have adopted comparable recordkeeping rules that were also effective January 1,
2002. It's important in compiling national statistics that all employers use
the same criteria for injuries and illnesses. For other recordkeeping
provisions, for example, industry exemptions, state requirements may be more
stringent than federal requirements.
Slide 10 - For More Information
Presenter's Note: Provide handout on most recent OSHA Recordkeeping Page from the OSHA website. Script:
This system is a big improvement over the old - for everyone.
Better records will help us better track injuries and illnesses and identify
hazards that need further attention. Both workers and employers will