The recording and reporting requirements of Part 1904 are establishment based. Under most circumstances, a campus is a single physical location and considered as a single establishment. Under limited conditions, you may consider two or more separate facilities that share a single location to be separate establishments. You may divide one location into two or more establishments only when: 1) Each facility represents a distinctly separate business; 2) Each facility is engaged in a different economic activity; 3) No one industry description applies to the joint activities of the establishments; and 4) Separate reports are routinely prepared for each establishment on the number of employees, their wages and salaries, sales or receipts, and other business information.
Q: My company operates multiple facilities on a campus setting. Each facility has less than 250 employees, but the campus has more than 250 employees. How should I count my employees to determine if I have to electronically provide OSHA my injury and illness records?
FAQ ID: 590
Source: FAQs
Q: My establishment is in an industry listed on the “Non-Mandatory Appendix A to Subpart B - Partially Exempt Industries” but that NAICS code no longer exists in the 2017 NAICS coding system. Does that mean I need to start filling out the recordkeeping forms
No. If your establishment is classified in one of the 2007 NAICS codes listed on the Partially Exempt Industries webpage, it is partially exempt for OSHA's recordkeeping requirements, even if a corresponding 2017 or 2022 code does not exist.
For more information, explore OSHA's Recordkeeping Requirements.
FAQ ID: 2-4
Source: FAQs
Q: My firm has multiple establishments that do different things. Which determines whether I have to submit data for those establishments, the industry classification of the firm or the industry classification of the establishment?
The electronic reporting requirements are based on the industry classification of the establishment, not the industry classification of the firm. An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed. A firm may be comprised of one or more establishments. Two groups of establishments are required to electronically submit data to OSHA: (1) Establishments with 20-249 employees in certain industries, and (2) Establishments with 250 or more employees in industries subject to OSHA's recordkeeping requirement. Establishments that are partially exempt from OSHA's recordkeeping due to industry are not required to submit data, regardless of establishment size.
FAQ ID: 587
Source: FAQs
Q: Once an employer has recorded a case involving days away from work, restricted work or medical treatment and the employee has returned to his regular work or has received the course of recommended medical treatment, is it permissible for the employer to delete the Log entry based on a physician's recommendation, made during a year-end review of the Log, that the days away from work, work restriction or medical treatment were not necessary?
The employer must make an initial decision about the need for days away from work, a work restriction, or medical treatment based on the information available, including any recommendation by a physician or other licensed health care professional. Where the employer receives contemporaneous recommendations from two or more physicians or other licensed health care professionals about the need for days away, a work restriction, or medical treatment, the employer may decide which recommendation is the most authoritative and record the case based on that recommendation. Once the days away from work or work restriction have occurred or medical treatment has been given, however, the employer may not delete the Log entry because of a physician's recommendation, based on a year-end review of the Log, that the days away, restriction or treatment were unnecessary.
For more information, explore OSHA's Recordkeeping Requirements.
FAQ ID: 7-10
Source: FAQs
Q: Our insurance agent said we need to keep an OSHA log. Where do we get the forms and directions to complete them?
The OSHA Form 300 can be found and downloaded from the OSHA website at http://www.osha.gov/recordkeeping/RKforms.html Please review the tutorial at http://www.osha.gov/recordkeeping/tutorial.html for an overview on how to complete the forms. You will also find links to the Regulatory Text of the Recordkeeping Rule, Frequently Asked Questions, Fact Sheets and other general information regarding recordkeeping at http://www.osha.gov/recordkeeping/index.html.
FAQ ID: 173
Source: OSHA e-correspondence
Q: Section 1904.7(b)(5)(ii) of the rule defines first aid, in part, as "removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means." What are "other simple means" of removing splinters that are considered first aid?
"Other simple means" of removing splinters, for purposes of the first-aid definition, means methods that are reasonably comparable to the listed methods. Using needles, pins or small tools to extract splinters would generally be included.
For more information, explore OSHA's Recordkeeping Requirements.
FAQ ID: 7-11
Source: FAQs
Q: Since the new system proposes to do away with the distinction between injuries and illnesses, is there guidance on how to classify cases to complete column M on the OSHA 300 Log?
An injury or illness is an abnormal condition or disorder. Employers should look at the examples of injuries and illnesses in the "Classifying Injuries and Classifying Illnesses" section of the Recordkeeping Forms Package for guidance. If still unsure about the classification, employers could use the longstanding distinction between injuries that result from instantaneous events or those from exposures in the work environment. Cases resulting from anything other than an instantaneous event or exposure are considered illnesses.
For more information, explore OSHA's Recordkeeping Requirements.
FAQ ID: 29-6
Source: FAQs
Q: The old rule required the recording of all occupational illnesses, regardless of severity. For example, a work-related skin rash was recorded even if it didn't result in medical treatment. Does the rule still capture these minor illness cases?
No. Under the new rule, injuries and illnesses are recorded using the same criteria. As a result, some minor illness cases are no longer recordable. For example, a case of work-related skin rash is now recorded only if it results in days away from work, restricted work, transfer to another job, or medical treatment beyond first aid.
For more information, explore OSHA's Recordkeeping Requirements.
FAQ ID: 7-1
Q: This question involves the following sequence of events: Employee A drives to work, parks her car in the company parking lot and is walking across the lot when she is struck by a car driven by employee B, who is commuting to work. Both employees are seriously injured in the accident. Is either case work-related?
Neither employee's injuries are recordable. While the employee parking lot is part of the work environment under section 1904.5, injuries occurring there are not work-related if they meet the exception in section 1904.5(b)(2)(vii). Section 1904.5(b)(2)(vii) excepts injuries caused by motor vehicle accidents occurring on the company parking lot while the employee is commuting to and from work. In the case in question, both employees' injuries resulted from a motor vehicle accident in the company parking lot while the employees were commuting. Accordingly, the exception applies.
For more information, explore OSHA's Recordkeeping Requirements.
FAQ ID: 5-9
Source: FAQs
Q: Under paragraph 1904.29(b)(9), the employer may use some discretion in describing a privacy concern case on the log so the employee cannot be identified. Can the employer also leave off the job title, date, or where the event occurred?
Yes. OSHA believes that this would be an unusual circumstance and that leaving this information off the log will rarely be needed. However, if the employer has reason to believe that the employee's name can be identified through this information, these fields can be left blank.
For more information, explore OSHA's Recordkeeping Requirements.
FAQ ID: 29-3
Source: FAQs