OSHA recordkeeping requirements can be a complex and confusing. The requirements are numerous and vary depending on the size of your operation. Read on for OSHA guidance to help you understand OSHA requirements and how to comply with them.
Is my Habitat affiliate required to complete OSHA 300 logs?
If your affiliate had 10 employees or less in the previous year, you are exempt from keeping OSHA injury and illness records.
However, Habitat for Humanity affiliates with more than 10 employees are subject to OSHA recordkeeping requirements. Affiliates must record when an employee is injured or contracts an illness at work and at least one of the conditions of the general recording criteria in 29 CFR 1904.7 is met.
An injury is considered work-related when an event or exposure in the work environment caused or contributed to the condition (or significantly aggravated a pre-existing condition). With some exceptions, work-relatedness is presumed when injuries occur in the work environment. Refer to 29 CFR 1904.5 “Determination of work-relatedness” for more information.
OSHA defines the work environment as the establishment and other locations where employees are working or are present as a condition of employment. This includes physical locations and equipment or materials used by the employee during work.
Which injuries should be recorded?
OSHA defines a recordable work-related injury or illness as:
- A fatality
- An injury or illness that results in loss of consciousness, days away from work, restricted work or transfer to another job
- An injury or illness requiring medical treatment beyond first aid
- A diagnosis of cancer, chronic irreversible diseases, fractured or cracked bones or teeth and punctured eardrums
- A case involving needlesticks and sharp injuries, medical removal, hearing loss or tuberculosis
- A significant injury or illness diagnosed by a physician or other licensed health care professional
Medical treatment versus first aid
OSHA defines first aid as any of the following:
- Using an over the counter medication
- Cleaning, flushing or soaking wounds on the surface of the skin
- Using wound coverings such as bandages, gauze pads or butterfly bandages (other methods such as sutures and staples are considered medical treatment)
- Hot or cold therapy
- Any non-rigid means of support, such as elastic bandages, wraps and non-rigid back belts
- Using temporary immobilization devices like splints, slings and braces
- Drilling of a fingernail or toenail to relieve pressure or draining fluid from a blister
- Eye patches
- Removing foreign bodies from the eye with irrigation or a cotton swab
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
- Finger guards
- Massage (physical therapy or chiropractic treatment are considered medical treatment)
- Drinking fluids for relief of heat stress
Privacy concern cases
In certain cases, the employee’s name should not be recorded on the OSHA log. These are considered privacy concern cases and may involve:
- An injury or illness to an intimate body part or the reproductive system
- An injury or illness resulting from a sexual assault
- A mental illness
- A work-related HIV infection, hepatitis case or tuberculosis case
- Needlestick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material
- Any other illness, if the employee requests his or her name not be entered
The rule requires the employer to enter enough information to identify the cause of the incident and the general severity of the injury or illness but allows the employer to exclude details of an intimate nature.
The employer must maintain a separate, confidential list of privacy concern cases with the case number from the log and the employee’s name. This list is required to maintain the log and to ensure the information is available should a government representative need the information during a workplace inspection.
Case recording and log posting time frames
Each recordable injury or illness case must be recorded on the OSHA 300 Log and the Form 301 Incident Report within seven calendar days after the employer receives notice that the injury or illness occurred.
The OSHA form 300 A must be posted by February 1st of the following year, summarizing all injuries from the previous year. The log must be visible from February 1st until April 30th. In addition, all records must be maintained on site for at least five years.
What forms must be completed?
The OSHA injury and illness recordkeeping forms include:
- Log of Work-Related Injuries and Illnesses (OSHA Form 300)
- Summary of Work-Related Injuries and Illnesses (OSHA Form 300A)
- Injury and Illness Incident Report (OSHA Form 301)
Employers must fill out the log and the incident report if a recordable work-related injury or illness has occurred. Employers must fill out and post the summary annually, even if no recordable work-related injuries or illnesses occurred during the year.
OSHA has many tips for recording illnesses and injuries correctly each year, but if you need more assistance, contact your Lockton Affinity account manager. We are dedicated to helping affiliates like yours.