Safety and Health Recordkeeping
No operation can be successful without adequate recordkeeping, which enables the management of each organization to learn from past experience, and to make corrections for future operations. Records of leading indicators, such as near-misses, hazards identified and eliminated, training completed, as well as lagging indicators: accidents, work-related injuries, illnesses and property losses serve as resources for information. Leading indicators demonstrate proactive action taken to eliminate accidents and incidents. Lagging indicators show where there are problems which need to be addressed.
OSHA recordkeeping requires information on accidents to be gathered, recorded, reported, and stored. Upon review, causes can be identified and control procedures instituted to prevent the illness or injury from recurring. Keep in mind any inspection of a workplace may require the employer to demonstrate the effectiveness of their program.
Injury and illness recordkeeping requirements under OSHA require a minimum amount of paperwork.
These records give employers one measure for evaluating the success of their safety and health activities; success would generally mean a reduction or elimination of employee injuries or illnesses during a calendar year. Five important steps are required by the OSHA recordkeeping system:
- Each employer (unless exempt by size or industry) must record each work-related fatality, injury, or illness that is a new case, or meets one or more of the general recording criteria specified.
- Record each injury or illness on the OSHA Log of Occupational Work Related Injuries and Illnesses (Form 300) according to its instructions.
- Prepare an Injury and Illness Incident Report (Form 301), or equivalent.
- Annually review and certify the OSHA Form 300 and post the Summary of Work-Related Injuries and Illnesses (Form 300A) no later than February 1 and keep it posted where employees can see it until April 30.
- Maintain the last five years of these records in your files.
During the year, regularly review these records to see where injuries and illnesses are occurring. Look for any patterns or repeat situations. These records can help identify hazardous areas in the workplace and pinpoint where immediate corrective action is needed.
Since the basic OSHA and state plan records are for reportable injuries and illnesses only, Behavior Safety Associates advises employers to consider expanding their recordkeeping system to include all incidents relating to workplace safety and health, even those where no injury or illness resulted. Such information can assist in pinpointing unsafe acts, conditions or procedures.
Injury and illness records may not be the only records employers need to maintain. OSHA and state plan standards concerning toxic substances and hazardous exposures require records of employee exposure to these substances and sources, physical examination reports, employment records, and other information. California employers using any regulated carcinogens have additional reporting and recordkeeping requirements.
Essential records, including those legally required for workers’ compensation, insurance audits, and government inspections, must be maintained for as long as required.
For most employers, OSHA and state plan standards also require employers to keep records of steps taken to establish and maintain their safety and health (Injury and Illness Prevention) program. They must include:
- Records of scheduled and periodic inspections as required by the standard to identify unsafe conditions and work practices. The documentation must include the name of the person(s) conducting the inspection, the unsafe conditions and work practices identified, and the action taken to correct the unsafe conditions and work practices. The records are to be maintained for at least one year. However, employers with fewer than 10 employees may elect to maintain the inspection records only until the hazard is corrected.
- Documentation of safety and health training required by standards for each employee. The documentation must specifically include employee name or other identifier, training dates, type(s) of training and the name of the training provider. These records must also be kept for at least one year, except that training records of employees who have worked for less than one year for the employer need not be retained beyond the term of employment if they are provided to the employee upon termination of employment.
Also, employers with fewer than 10 employees can substantially comply with the documentation provision by maintaining a log of instructions provided to the employee with respect to the hazards unique to the employees’ job assignment when first hired or assigned new duties. Some relief from documentation is available for employers with fewer than 20 employees who are working in industries that are designated low-hazard industries, and for employers with fewer than 20 employees who are not high-hazard industries and who have a Workers’ Compensation Experience Modification Rate of 1.1 or less. For these industries, written documentation of the Injury and Illness Prevention Program may be limited to:
- Written documentation of the identity of the person or persons with authority and responsibility for implementing the program
- Written documentation of scheduled periodic inspections to identify unsafe conditions and work practices
- Written documentation of training and instruction.