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OSHA Recordkeeping Requirements: Your Ultimate Guide

Author • Katie Palmer

OSHA Recordkeeping Requirements: Your Ultimate Guide

Date: 2021/04/21


OSHA recordkeeping requirements are vital knowledge for any supervisor or manager. This blog post is your Ultimate Guide to understanding OSHA recordkeeping requirements!

OSHA Recordkeeping is Required

OSHA stands for the Occupational Safety and Health Administration. It is Federal Law, meaning it is legally required—not optional. OSHA applies to all employers in the U.S., although states have their own OSHA. State OSHA organizations supersede Federal OSHA, because they are more protective of the employee. 

Recordkeeping is mandated by various OSHA standards. Job hazard exposure must be documented as well. Program requirements must be explained to employees.

Who do these OSHA laws apply to?

Companies with 11 or more employees are generally covered by the OSHA recordkeeping laws. Employers in exempt low-hazard industries are not subject to the OSHA recordkeeping and reporting laws. 

Employers are required to create a system for reporting illnesses and injuries, telling employees about the process, and accommodating requests to review the records kept.

Why is Recordkeeping Important?

OSHA recordkeeping is a critical way to identify problems in the Workplace Safety Program. Recordkeeping helps identify causes of accidents and illnesses. Using this data, prevention strategies can then be created and implemented.

Incident and exposure records provide valuable information to promote occupational safety and health.

When are Incidents Deemed Work-Related?

Incidents are deemed work-related if the condition was caused, or if a pre-existing condition was aggravated, by an event or exposure in the workplace. 

However, there are exceptions to this standard. Exceptions include eating and drinking, common colds and the flu, exercise programs, and mental illnesses.

Although many people try to claim COVID-19 and the flu are the same, COVID-19 is included in OSHA recordkeeping and reporting requirements.

If the employee experienced an injury that was work-related, and if the incident falls within the OSHA standard, it should be recorded. If the injury or illness is not new, the previously-reported incident should be updated.

What are the OSHA Recordkeeping Forms?

OSHA forms include:

  • Form 300: Log of Injuries and Illnesses
  • Form 301: Individual Incident Report
  • Form 300A: Annual Workplace Summary

These forms must be kept for 5 years.

Medical and exposure records must be maintained for the duration of employee employment, plus 30 years. Summaries of monitoring and recording data must also be kept for 30 years.

Workplace records must include: 

  • Death
  • Days off work
  • Restricted duties or transfer
  • Medical treatment
  • Loss of consciousness 
  • Diagnosis of severe injury

The number of calendar days away from work must be recorded, as well as the details of the medical treatment. 

What are the OSHA Requirements?

OSHA requires: 

  • Establishment of a safety program
  • Maintenance of records
  • Ongoing training

Who should be involved in the Workplace Safety Program?

  • Employees
  • Safety Committee Partners
  • Department Managers
  • First-line Supervisors 
  • Accident Investigation Team Members 

Under Federal law, employers are responsible for assuring access to medical records by: 

  • Employees
  • Employee Representatives 
  • Government Agencies 

Management and Supervisor Involvement

Management involvement in safety recordkeeping is essential! Management support should be visible. Managers should attend training along with employees—interaction is critical.

Supervisors must understand recordkeeping requirements and be able to complete proper paperwork in the event of an injury. Supervisors should also attend the same training as other employees. They should also become proactively involved in safety discussions and processes.

Supervisor attitude is a key element of compliance. No injury or near-miss should be subjected to ridicule!

Ultimately, supervisor involvement in safety issues can save lives.

Employee Involvement 

OSHA regulations enhance employee involvement in the recordkeeping process. Employees should become involved in recordkeeping issues and contribute to corrective actions aimed at solving problems.

Employee behavior affects on-the-job safety. Employees are expected to be proactive and professional. Most importantly, employees are expected to report safety problems and deficiencies. Follow-up is vital! 

In-Depth OSHA Reporting Requirements

Recordkeeping rules require reporting for an employee death, or for medical treatment of an employee. Reporting means contacting the Occupational Health and Safety Administration (OSHA). Reporting could launch a full OSHA inspection.

Reporting requirements include: 

  • Number of restricted workdays
  • Transfer to less-demanding job
  • Loss of consciousness
  • Physical diagnosis

Certain injuries must be reported:

  • Needle punctures or sharps injuries
  • Noise shift averaging 10db or more
  • Diagnosis of tuberculosis 

Exposure to tuberculosis and cases involving the removal of an employee under provisions of the OSHA health standard must be reported. 

Employers must report any fatality or the hospitalization of 3 or more employees.

How to Report to OSHA

You can report to OSHA by:

  • Calling the nearest OSHA office
  • Calling the OSHA 24-hour phone service at 1-800-321-6742
  • Reporting online via electronic submission

Right to Review 

Workers and their representatives have the right to review the employer’s OSHA 300 Log and obtain copies of Form 301. Upon request, the employer must furnish access to the OSHA 300 log within 15 days. If there is a delay in access, the employer must provide a written explanation within 15 days.

Records should be provided at no cost.

Records that are difficult to copy, like x-rays, should be loaned for a reasonable amount of time.

The employer is within the law to release records only to a physician or other designated representative.

Analysis and Disclosure

In an effort to continually improve workplace safety, employers may generate an analysis of exposure or medical records concerning employee working conditions or workplace safety. Employers must allow access to the analysis of workplace safety to employees, employee representatives, and OSHA Inspectors.

Trade Secrets

Trade secrets are sometimes disclosed when exposures to toxic substances occur. When deletion of this trade secret information hinders evaluation of the records, employers must provide alternate information sufficient to identify where and when the exposure occurred.

One exception involves requests from physicians or healthcare professionals during an emergency. In these situations, trade secret information should not be deleted, and should be provided.

In non-emergency situations, employers must disclose the specific chemical ID if:

  • Employee wants to assess chemical hazard
  • Conduct sampling of workplace exposure
  • Conduct pre-assignment or medical surveillance
  • Medical treatment is provided to exposed employees
  • Personal protective equipment (PPE) is being selected
  • Protective measures are being designed 

Individuals authorized to obtain trade secret information must agree in writing that they will not use the information for any reason other than the health needs agreed upon.

Transfer of Records

If the business closes, OSHA recordkeeping files must be transferred to a successor employer. If there is no successor employer, employees must be told of the right to access records 90 days before the business closes.

When an employer is going out of business and intending to destroy records, they must notify at least 3 months before the records are destroyed.

Need OSHA help?

You should understand all the OSHA recording and reporting requirements after reading this ultimate guide. But if you need more OSHA help, Smart Training is here for you.

If you need help with OSHA Compliance, Smart Training is here to make it easier for you. All our compliance solution packages – Platinum+ and Essentials – offer online OSHA training, OSHA Written Programs, compliance checklists, Job Hazard Analyses, and monthly safety and security meetings. With Platinum+, you’ll also get your own Compliance Adviser and a yearly compliance inspection. 

Interested in learning more? Schedule a demonstration with one of our Compliance Advisers.

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