Recording Occupational Injuries & Illnesses
One of your most productive employees hobbles up to youwith a sore back. “It’s been hurting ever since I moved that puncher tothe other side of the greenhouse,” he says. “I think I need to go tothe doctor.” What do you do? How do you report it? Who do you tell? How doyou protect yourself? Some of the forms you’ll need to fill out have new namesand new numbers, and as with most governmental procedures, there are always newexemptions, new rules, new deadlines and new guidelines. Read on to keepyourself apprised of the Occupational Safety & Health Administration (OSHA)changes so you’ll be ready if that employee does come to you with an illness orinjury.
Names of new forms.The new forms are called OSHA Form 300, Log of Work-Related Injuries andIllness and Form 301, Injury and Illness Incident Report. The OSHA 300 logreplaces the OSHA 200 log, and Form 301 replaces Form 101. Á
Appropriate forms and when to use them. Employers mustnow use the 300-numbered forms. The employer may continue to substituteequivalent forms, such as insurance reports, for the supplemental informationOSHA 301, Incident Report form. Records may be kept in paper format or on acomputer, as long as the computer form is equivalent to the OSHA 300 log.
Small employer exemption. A partial exemption for small employers remains the same. Thoseemployers with 10 or fewer employees at all times during the last calendar yeardo not need to keep OSHA injury and illness records, unless required toparticipate in the annual survey. If at any time during the last calendar yearyour company had 10 or more employees, you must keep a log of injuries andillnesses. The number of employees counted is for your entire company, not justa single location.
SIC code exemption.A partial exemption for employers in some establishments in certain industriesremains. Those employers whose primary SIC code is among the exempted do notneed to keep injury and illness records, unless contacted by OSHA toparticipate in the survey. Appendix A to Subpart B (following 1904.3) containsa list of those SIC codes that are exempt. The exempt businesses are, for themost part, those businesses that do have and are expected to have very lowinjury and illness rates, such as retail stores, offices, restaurants and thelike. There seems to be no consideration of ergonomic injuries and illnesses atthis point. Some of the exempted SIC codes might be expected to have highergonomic injury rates. If you have access to the net, you can go towww.osha.gov/oshstats/sicser.html to determine your SIC code number.
New rule contents.The new rules, as they will be printed in the Code of Federal Regulations(CFR), are much more detailed in explaining how to determine which injuries andillnesses must be recorded on the OSHA 300 log and how to keep the recordsaccurate. Basic rules for recording injuries and illnesses have changed verylittle, but in the past much of this information was contained in OSHAassistance guides and interpretation letters. When you get your new materialsor if you have already received them, read over them and call if you have anyquestions.
Recording deadlines.The new rules have changed how the time frame is expressed, but they have notchanged the actual amount of time allowed for getting injuries and illnessesrecorded to any great degree. The new rules require all injuries and illnessesto be entered on the form within seven calendar days of the employer receivinginformation that a recordable injury or illness has occurred. The old rulesrequired entry within six working days. The 2-day weekend cushion has beeneliminated.
Summary posting requirements. The annual summary posting period is increasingstarting with the posting of the year 2002 summary portion in 2003. The summaryportions of your OSHA 300 logs for 2002 must be posted from February 1 throughApril 30, 2003. The new forms have separate pages for the log and summaryportions and a worksheet to help you fill out the summary portion.
Retention of forms. Thenew forms must be kept five years following the end of the calendar year thatthese records cover, the same as with the old forms. You must continue to keepthe old forms for five years, discarding the 6-year-old form as you archive themost recent form.
Updating old forms in storage. You will also be required to update 300 logs instorage as is currently required for the OSHA 200 log. Your archived forms mustbe updated if employees die or become Á more severely disabled fromwork-related injuries or illnesses already recorded. Updating will not berequired for the annual summary or Form 301s (or equivalents). When the newforms become the required form of use, updating old OSHA 200 logs or 101 formsin storage will not be required.
Reporting fatalities and multiple hospitalizations. The requirement for reporting fatalities andmultiple hospitalizations remains the same – report orally to OSHA within eighthours of learning about the occurrence. Report in person or call your nearestOSHA office or call the central reporting number for the Washington, D.C.office – (800) 321-6742.
Annual survey.The annual Bureau of Labor Statistics survey will continue to be conducted. Anyemployer, regardless of whether they normally have to keep these injury andillness records, must participate in the annual survey of work-related injuriesand illnesses if notified by OSHA.