Question: May I use a different form as an acceptable substitute for the OSHA forms for recordkeeping purposes?

Answer:

You may only use a different form if it is an equivalent form. Under paragraph 1904.29(b)(4), an equivalent form is one that has the same information, is as readable and understandable, and is completed using the same instructions as the OSHA form it replaces. Equivalent forms can be maintained in any file format (e.g., Excel, CSV) provided that these requirements are met.

Question: May I use a different form as an acceptable substitute for the OSHA Form 300-A Annual Summary?

Answer:

You may only use a different form if it is an equivalent form. Under paragraph 1904.29(b)(4), an equivalent form is one that has the same information, is as readable and understandable, and is completed using the same instructions as the OSHA form it replaces. Under paragraph 1904.32(b)(2)(iii), if you use an equivalent form to replace the OSHA 300-A Annual Summary, it must also include the employee access and employer penalty statements found on the OSHA 300–A Summary form. Equivalent forms can be maintained in any file format (e.g., Excel, CSV) provided that these requirements are met. However, equivalent forms used as a substitute for the OSHA Form 300-A Annual Summary must also be certified and posted annually as required under paragraph 1904.32.

Question: May an employer keep the OSHA injury and illness records for all their establishments at the headquarters.

Answer:

Yes. Section 1904.30(b)(2) provides that employers can keep injury and illness records for all establishments at their headquarters or other central location. However, section 1904.30(b)(2) makes clear that this is only permitted when the employer can (1) transmit information about injuries and illnesses from the establishment to the central location within seven calendar days of receiving information that a recordable injury or illness has occurred, and (2) produce copies of the injury and illness forms when access to them is needed by a government representative, employee or former employee, or an employee representative, as required by sections 1904.35 and 40. Also, employers must physically post the OSHA 300A Annual Summary at each establishment where the employer maintains an OSHA form 300 from February 1st through April 30th each year per 1904.32(b)(6).

Question: Are work-related human bites recordable on the OSHA form 300 when the skin is broken, and the wound is bleeding?

Answer:

A work-related injury or illness resulting from a human bite is recordable if it meets any of the recording criteria (i.e. if it requires medical treatment beyond first aid, restricted work activity or transfer to another job, days away from work, or results in a loss of consciousness).

Question: An employee's normal shift is 6:00 PM to 2:30 AM. The employee starts his shift at 6:00PM on Monday and sustains a work-related injury at 12:30AM Tuesday. The injury results in the employee going to a physician who excuses the employee from work for Tuesd

Answer:

Days away from work and days of restricted work activity are determined by calendar days rather than scheduled work shifts. You begin counting days away from work or days of restricted work activity on the day after the injury occurred or the illness began. Because the employee was injured Tuesday and returned to work on the subsequent day, Wednesday, there are no days away from work involved in this scenario. However, because the employee was unable to work part of the workday (Wednesday 12:00 AM to 2:30AM), the injury resulted in one day of restricted work activity.

Question: How many calendar days are to be counted in the case of a work-related fatal injury or illness?

Answer:

None. Employers are required to record a case based on the most severe outcome, so even where an employee has sustained days away from work before that employee dies, the fatality would be the most severe outcome. In the case of a work-related fatality, enter a checkmark in column G (death) on the Form 300.

Question: If an employee has x-rays or other diagnostic procedures, does that make a case recordable?

Answer:

No. X-rays and other diagnostic procedures are not considered medical treatment and do not make a case recordable per section 1904.7(b)(5)(i)(B).