The Occupational Safety and Health Administration (OSHA) considers the process of reporting injuries and illnesses, recording the information and analyzing those records to be key components of efforts to protect the safety of workers, and the agency expects employers to take their obligations seriously.
These obligations include recording all significant work-related injuries and illnesses and making a summary available to employees, as well as promptly reporting fatalities and severe injuries to OSHA.
What employers might not realize is that tracking injuries and illnesses and reporting the most severe ones also can help their bottom lines by allowing them to identify and correct hazards before they cause further damage and loss of productivity for their companies.
REPORTING AND RECORD KEEPING REQUIREMENTS
OSHA’s reporting and record keeping rules were updated as of Jan. 1, 2015. The most significant change for employers was a new requirement to report severe injuries—defined as an amputation, in-patient hospitalization or loss of eye—within 24 hours. (The long-standing requirement to report any work-related fatality or catastrophe to OSHA within eight hours was unchanged.)
In addition, some changes were made in determining which employers and industries are exempt from OSHA’s routine record keeping requirements. In general, businesses with 10 employees or fewer are exempt. Also exempt are certain low-hazard industries. As of Jan. 1, 2015, the list of exempt industries, available at www.osha.gov/recordkeeping/ppt1/RK1exempttable.html, changed slightly, and newly covered industries, available at www.osha.gov/ recordkeeping2014/reporting_industries.html, were added.
RECORD KEEPING OBLIGATIONS
All employers who are required to keep records must keep a log of 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. In addition, employers must record significant work-related injuries or illnesses diagnosed 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.
From Feb. 1 to April 30 each year, employers who are required to keep a log must post in a common employee area OSHA’s Form 300A, available at www.osha.gov/recordkeeping/RKforms.html, which summarizes the job-related injuries and illnesses logged during the previous year.
Visit OSHA’s Recordkeeping webpage, www.osha.gov/recordkeeping/index.html, for more information on recordkeeping requirements.
As noted previously, all employers are now required to report work-related severe injuries within 24 hours of learning about them. It is important for all employers under federal OSHA jurisdiction to remember that they must report these incidents even if they are normally exempt from the agency’s record keeping requirement in light of the company size or industry.
Employers have three options for reporting workplace fatalities and severe injuries to OSHA:
- They can call the nearest area office during normal business hours. These phone numbers can be found through the map of OSHA offices on the agency’s website at www.osha.gov/html/ RAmap.html.
- They can call the 24-hour OSHA hotline at 800-321-6742 (OSHA).
- They can report online at www.osha.gov/pls/ser/serform.html.
Whatever method employers use to contact OSHA, they should be prepared to supply the name of the business, the names of employees affected, the location and time of the incident, a brief description of the incident and a contact person and phone number.
In the first full year of the new requirement, employers submitted nearly 12,000 reports, including more than 7,000 for hospitalizations and more than 2,500 for amputations.
A fact sheet and wallet card in English and Spanish are available at www.osha.gov/recordkeeping2014/OSHA3744.pdf and at http://1.usa.gov/1TH2hNZ, respectively, to help employers comply with the reporting requirements.
PREVENTING RECORDABLE INCIDENTS
Of course, the easiest way for employers to stay in compliance with OSHA’s record keeping and reporting requirements is to prevent workers from suffering any significant workplace injuries or illnesses.
OSHA’s Recycling webpage, www.osha.gov/SLTC/recycling/index.html, contains information on protecting workers from hazards associated with recycling specific materials—such as scrap metal, electronics, batteries and used oil and other chemicals, as well as hazards that are common across various types of recycling—such as traffic safety, moving machine parts, unexpected machine startup, lifting injuries and slips, trips and falls.
In addition to these online resources, OSHA offers employers with limited resources free on-site consultations to analyze potential or existing hazards at their places of business and to develop safety and health management programs tailor-made to their needs.
OSHA’s On-site Consultation Program, www.osha.gov/dcsp/smallbusiness/consult.html, offers free and confidential safety and occupational health advice to small and midsized businesses. In 2015 the program provided free and confidential safety and occupational health advice to 27,871 small and midsized businesses across the country. The program recognizes that while most employers want to keep their workers safe and healthy on the job, smaller businesses often lack the resource of an on-site safety professional to find and fix hazards. Last year, 87 percent of consultations were conducted at businesses with 100 or fewer employees.
Consultants from state agencies or universities work with employers to identify workplace hazards, provide advice on compliance with OSHA standards and assist in establishing injury and illness prevention programs. Priority is given to high-hazard work sites in industries such as manufacturing and construction. In 2015, consultants identified and helped employers eliminate more than 140,000 total hazards, protecting an estimated 3.5 million workers from possible injury, illness or death.
The agency’s on-site consultation services are separate from enforcement and do not result in penalties or citations for employers who use the service. Employers can visit www.osha.gov/dcsp/small business/consult_directory.html to find local On-site Consultation Program offices.
OSHA representatives are eager to help employers minimize the number of injuries and illnesses they must record or report to the agency by creating a culture of safety that protects workers and profits.