There are many responsibilities and initiatives that go in to developing a comprehensive and effective Environmental, Health, and Safety program. However, one area of focus that is often overlooked and underappreciated is record-keeping. Yet maintaining accurate, up-to-date, and accessible records is a foundational component in workplace safety. Not only are workplace injury and illness records required by federal law, these metrics play a valuable role in safety statistics, both within individual workplaces and in data collected by agencies such as the Center for Disease Control, OSHA, and the National Institute for Occupational Safety and Health. Such data collection helps show trends and identify common injuries and illnesses so that preventative measures can be developed.
REQUIRED RECORDS & SUBMISSION
Unless your business has 10 for fewer employees at all times during the calendar year or your business is classified as an exempt industry (see list here: https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html), you are required to complete and retain the following forms:
Log of Work-Related Injuries and Illnesses (OSHA Form 300),
Summary of Work-Related Injuries and Illnesses (OSHA Form 300A), and
Injury and Illness Incident Report (OSHA Form 301).
The OSHA 300 Form must be completed for every recordable workplace injury and illness and updated with any new incidents. The OSHA 301 Form is a more detailed account of the recordable incident and should correlate with recorded incidents on the 300 Form. Employers must also fill out and post the OSHA 300A Form, even if there were no recordable incidents. The 300A Form must be posted prominently in the workplace by February 1st each year and remain posted until April 30th of the same year. All forms must be retained for a minimum of 5 years. Additionally, all employers, even those exempt by size or industry classification, must report all incidents that result in a fatality within 8 hours. Similarly, any incident that results in amputation, in-patient hospitalization, or loss of an eye must be reported within 24 hours, regardless of size or classification. For establishments with 20+ employees, the OSHA 300A Form must be electronically submitted by March 2nd of every year. The previous submission deadline was July 1st. Establishments exempt from this requirement include those found on this classification list: https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html. Exemptions apply only at the establishment level, not for the firm as a whole.
TIPS FOR SUCCESS
Successfully managing record keeping requires knowledge of the various OSHA forms, workplace procedures for incident reporting, and cross training between management and human resource staff. Specific considerations should also include:
Do employees and management know what constitutes a recordable incident?
Is there a procedure for reporting an incident and do employees know the process?
Is there cross training for record-keeping responsibilities?
Do employees have access to records?
Are records used for internal performance metrics?
Beyond OSHA requirements, how can workplace safety be measured?
Administrative aspects of workplace safety are just as essential as injury and illness prevention strategies. Accurate record-keeping represents data that can be used to identify safety gaps, develop safety strategies, and improve overall workplace conditions that are safer and more operationally viable.
"Progress Demands Change"