1-Explain how to record an work-related injury suffered by a temporary worker.2-Explain how to record an work-related injury suffered by a contractor worker.
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Safety Management
Peer-Reviewed
Recordkeeping
Navigating OSHA’s Requirements
By Lori Schroth
I
njury logs are among the first items reviewed
and evaluated during an OSHA compliance inspection. Although the agency provides resources and guidance to help employers maintain injury
and illness logs, many employers fail to accurately
record each case, resulting in numerous OSHA citations each year. Claiming ignorance for not properly
recording cases on the logs will not help an employer avoid citations. OSHA expects recordkeepers to
know and understand the regulations.
OSHA’s (1970) General Duty Clause says that
employers are responsible for complying with
established safety and health standards and for
ensuring that the workplace is free of recognized
hazards. Under this clause and established OSHA
regulations, employers must maintain
a reporting and recordkeeping system
IN BRIEF
to classify work-related injuries and ill•OSHA recordkeeping
nesses and track the outcomes of each
continues to be problematic case. Employers can use the OSHA Form
for many employers.
300, Log of Work-Related Injuries and
•SH&E professionals must
Illnesses (Figure 1); 300A, Summary of
be familiar with proper
Work-Related Injuries and Illnesses (FigOSHA recordkeeping prac- ure 2); and 301, Injury and Illness Incident
tices and recognize when
Report (Figure 3, p. 30), otherwise known
and how to record a case
as OSHA logs, to meet this requirement.
on the OSHA logs.
The designated recordkeeper(s) (com•This article reviews
monly SH&E professionals) must be fathe importance of OSHA
miliar with proper OSHA recordkeeping
recordkeeping, highlights
practices and recognize when and how to
common errors, discusses
record a case on the OSHA logs.
red flags that may catch an
OSHA inspector’s eye and
The Importance of Recordkeeping
offers recommendations to
OSHA logs provide employers with a
achieve success in record- means to collect, record and track working cases and maintaining
related fatalities, injuries and illnesses
OSHA logs.
(those to which OSHA recordkeeping
rules apply). The information gathered
from recording and investigating each
Lori Schroth, CSP, is a safety and occupational health professional at Concurrent
Technologies Corp. where she provides technical solutions, support and expertise
to numerous clients. She is a member of ASSE’s Western Pennsylvania Chapter, a
member of and publication coordinator for ASSE’s Public Sector Practice Specialty and a member of Women in Safety Engineering. She has worked in SH&E
for 6 years and has previous safety experience in the circuit board manufacturing
industry. Schroth holds a B.S. in Safety Sciences and a B.S. in Natural Sciences from
Indiana University of Pennsylvania, an M.S. in Occupational Safety, Health and Environmental Management from Columbia Southern University, and she is pursuing
a doctorate in business administration from California Southern University.
28 ProfessionalSafety
AUGUST 2013
www.asse.org
work-related incident provides employers an opportunity to collect critical workplace-related information, including data on hazards that may not
have been previously identified. Employers can use
this information to make their workplaces safer
and to prevent injuries and illnesses.
Inspection programs can be enhanced by adding
the collective findings to inspection checklists used
in the work areas where the injury or illness occurred. The updated checklists will help inspectors
identify additional hazards as well. Contributing
factors can be incorporated into existing hazard recognition training to increase employee awareness.
Recording fatalities, injuries and illnesses also
provides a basis for trend analysis. Trending helps
employers identify commonalities, such as location of incidents, type of injury or illness, and the
machines, equipment or other devices involved.
Trending injury and illness data is easy to accomplish and the results are easy to understand. Even
though these data pertain to past events, the results
can identify repeat conditions and circumstances
that can be targeted to prevent recurrence. Recording work-related injuries, illnesses and fatalities
also allows an employer to calculate injury and
illness incidence rates [e.g., days away, restricted
and transferred (DART) and total case incident rate
(TCIR)]. Accurately tracking injuries and illnesses
ensures that a site’s calculated DART and TCIR are
accurate. Once calculated, the rates can be compared to industry averages published by BLS.
Injury rates offer a standardized way to measure
an organization’s performance historically and enable comparisons within and across industries. In
addition, organizations pursuing or participating
in OSHA’s Voluntary Protection Programs (VPP)
must demonstrate that they have below-industryaverage incidence rates.
Common Recordkeeping Concerns
Despite the recognized importance of recordkeeping, it continues to be the source of many
OSHA citations across all industries. Table 1 (p. 31)
shows a list of the Standard Industry Classification
(SIC) divisions that were cited for improper recordkeeping practices from October 2011 to September
2012; Figures 4 and 5 (p. 32) show the number of
issued citations and their corresponding costs.
Many of the recordkeeping violations are repeated by different organizations. Common issues
Figure 1
OSHA Form 300
involve record retention and certification; posting the OSHA 300A summary;
incident descriptions and classification;
reportable versus recordable incidents;
under- and overreporting; significant
injuries and illnesses; and workers’ compensation laws with OSHA recordkeeping regulations.
Retention of OSHA Logs
According to OSHA 29 CFR
1904.33(a), OSHA logs must be retained
for 5 years. If new cases emerge over
time or changes in the classification of
old cases occur, then the filed OSHA
Form 300 (where the original case was or
needs to be recorded) must be updated
accordingly.
Certification of OSHA Logs
OSHA 29 CFR 1904.32(b)(4) states
that a company executive must review
the information provided on the OSHA
Form 300 and verify that the data provided on the annual summary (OSHA
Form 300A) are correct and complete.
Some organizations believe that a safety manager may sign the logs, but this
is only true if this individual meets the
definition of a company executive.
According to OSHA, a company executive is one who “owns the organization,
acts as an officer at the organization,
is the highest ranking official working
at the establishment or the immediate
supervisor of this highest ranking official.” An individual meeting these requirements must certify the OSHA Form
300A by reviewing the information and
signing off on it before it is posted in the
workplace.
Figure 2
OSHA Form 300A
Posting the OSHA Form 300A
Many organizations have some misconceptions about when the OSHA Form 300A
must be posted. OSHA 29 CFR 1904.32(b)(6) specifically states that the annual summary must be
posted in a conspicuous area (e.g., bulletin boards,
lunchrooms) from Feb. 1 to April 30. In an interpretation letter from Dec. 18, 2003, OSHA states
that although the OSHA Form 300A must be posted, organizations can also elect to post the OSHA
Form 300. If they do so, all names must be removed
from the form before it is posted.
mediately understand what happened and use that
information to help determine whether an incident
should be documented as a new case or whether
an old case must be updated.
An example of poor documentation is, “Cut finger.” The statement does not describe which finger
was injured or how the injury occurred. A better
way to describe and document this case would be,
“Laceration on right thumb from contact with broken light fixture.”
Describing the Injury or Illness
Many recordkeepers also fail to provide an accurate description of the injury or illness. On the
OSHA Form 300, Section F advises, “Describe the
injury or illness, parts of the body affected, and
the object/substance that directly injured or made
the person ill” (Figure 6, p. 33). The recordkeeping
must be as specific as possible so that when referring to previously documented cases, one can im-
Case Classification
When a new case must be recorded on the OSHA
Form 300, discrepancies may exist in the boxes
checked under “Classify the Case.” Under this section, the form states that only one box should be
selected: death, days away from work, job transfer
or restriction, and other recordable cases (Figure
7, p. 34). However, recordkeepers may disregard
these instructions and check more than one box.
www.asse.org
AUGUST 2013
The information gathered
from recording
and investigating
each work-related
incident provides
employers an opportunity to collect
critical workplacerelated information,
including data on
hazards that may
not have been previously identified.
ProfessionalSafety 29
Figure 3
OSHA Form 301
Inspection programs can be
enhanced by adding the collective
findings of injury/
illness recordkeeping to inspection
checklists. The
updated checklists
will help inspectors
identify additional
hazards as well.
To know which box to check, one should evaluate the incident to identify the most serious outcome that resulted; this is an important practice to
apply when evaluating complex incidents. The box
that is marked is also supposed to be updated as an
incident progresses and as the most serious outcome changes.
Reportable vs. Recordable Incidents
Confusion also exists regarding whether a case is
reportable or recordable. All work-related incidents
should be reported following established site procedures; however, just because these injuries and illnesses are reported does not necessarily mean that
they should be recorded on the OSHA log. Mishap
reports may include near-misses and incidents involving first-aid treatment, or those that occurred
during voluntary participation in an activity.
Each reported incident must be thoroughly
evaluated to determine whether it is work-related.
OSHA 29 CFR 1904.5 states: “An employer must
consider an injury or illness to be work-related if an
event or exposure in the work environment caused
or contributed to the resulting condition or significantly aggravated a preexisting injury or illness.”
The regulation provides a definition for work environment and contains a list of situations and
circumstances of recordable and nonrecordable
injuries and illnesses. Therefore, each individual
case must be evaluated and compared against the
criteria in OSHA 29 CFR 1904.
Accurately determining the work-relatedness of
each case helps ensure that OSHA logs are correct to
prevent under- and overreporting. If questions arise,
recordkeepers can contact OSHA’s On-Site Consultation Program and receive free guidance (www
.osha.gov/dcsp/smallbusiness/consult.html).
Under- & Overreporting
Under- and overreporting are both recordkeeping concerns. Some organizations do not know the
types of incidents that must be recorded on the
OSHA logs while others neglect to include certain
incidents because of their effect on incidence rates
(e.g., may disqualify a site for VPP recogntion).
30 ProfessionalSafety
AUGUST 2013
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Underreporting may indicate that the
recordkeeper needs additional training or
guidance to appropriately recognize incidents that must be recorded; however,
this usually is not recognized until a site
is inspected or assessed and records (e.g.,
OSHA logs, incident investigation reports, injury reports) are reviewed. Ethical
issues also arise when sites intentionally
neglect to record certain incidents.
Under either circumstance, the recordkeeper is not meeting his/her duty to
provide accurate OSHA logs. As a result,
when Form 300A is posted, the site will
appear to be a safe place to work; however, the organization will still have the
potential to receive citations and may
overlook key factors that contribute to
workplace safety.
Overreporting injuries and illnesses is another issue commonly seen on OSHA logs. As noted, not
all injury and illness reports must be recorded. It is
great when an organization tracks additional data
(e.g., near-misses, first-aid cases) for continuous
improvement purposes; however, such information
should be documented and tracked separately from
the OSHA logs. Overreporting also reflects poorly
on the organization when the Form 300A is posted
and when the site’s incidence rates are calculated
and compared against the industry average.
Significant Injuries & Illnesses
Many employers are unaware that certain workrelated injuries and illnesses considered to be significant in nature must be recorded on the OSHA
logs regardless of the medical treatment and work
restrictions associated with each case. According to
OSHA 29 CFR 1904.7(b)(7), these injuries and illnesses include cancer, chronic irreversible diseases,
punctured eardrums, and fractured or cracked bones
or teeth. These cases are significant in nature because medical treatment may not be recommended
or provided when the cases are diagnosed; however, it is assumed that medical treatment will be
sought or provided as the injury or illness progresses
(OSHA, 2006). To maintain compliance, employers
must record these cases when they are diagnosed.
Workers’ Compensation Laws
& OSHA Recordkeeping
Recordkeepers must understand that in addition
to differences between cases that are reportable
and recordable, differences exist between workers’ compensation laws and OSHA recordable
incidents. Workers’ compensation is intended to
replace wages and the costs for medical expenses
for those injured on the job. OSHA recordables are
work-related incidents that meet the criteria outlined in the OSHA recordkeeping standard. If an
incident is submitted to workers’ compensation,
this does not automatically mean that the incident
should be recorded on the OSHA Form 300. Also,
consider the opposite circumstances too; if a workers’ compensation claim is denied, it does not nec-
Table 1
essarily mean that
the case should
be omitted or removed from the
OSHA Form 300.
All types of incidents can be submitted to workers’
compensation, including cases that
only result in firstaid medical treatment and other
incidents in which
the work environment did not
directly cause the
injury or illness.
Once again, the
work-relatedness
of each incident
must be evaluated
and compared
against the criteria
outlined in OSHA
29 CFR 1904.5.
OSHA Recordkeeping Red Flags
As noted, OSHA
logs are one of
the first items an
OSHA compliance
officer reviews and
evaluates during
an inspection. Numerous issues will
signal that recordkeeping practices
are not optimal.
SIC Divisions Cited for
Improper Recordkeeping Practices
OSHA  regulation  cited  
by  federal  OSHA  
1904.4  
Regulation  
Recording  criteria  
1904.5  
Determination  of  work-­‐
relatedness  
1904.6  
1904.7  
Determination  of  new  cases  
General  recording  criteria  
1904.8  
Recording  criteria  for  
needlestick  and  sharps  
injuries  
Recording  criteria  for  cases  
involving  medical  removal  
under  OSHA  standards  
Recording  criteria  for  cases  
involving  occupational  
hearing  loss  
Annual  summary  
1904.9  
1904.10  
1904.32  
Industry  divisions  cited  (%  of  citations  
related  to  the  OSHA  standard)  
D:  Manufacturing  (62%)  
F:  Wholesale  trade  (9%)  
I:  Services  (9%)  
E:  Transportation,  communications,  
electric,  gas  and  sanitary  services  (7%)  
G:  Retail  trade  (7%)  
C:  Construction  (3%)  
J:  Public  administration  (2%)  
A:  Agriculture,  forestry  and  fishing  (2%)  
D:  Manufacturing  (86%)  
E:  Transportation,  communications,  
electric,  gas  and  sanitary  services  (14%)  
I:  Services  (100%)  
D:  Manufacturing  (69%)  
I:  Services  (12%)  
C:  Construction  (6%)  
E:  Transportation,  communications,  
electric,  gas  and  sanitary  services  (6%)  
A:  Agriculture,  forestry  and  fishing  (4%)  
F:  Wholesale  trade  (2%)  
G:  Retail  trade  (2%)  
I:  Services  (83%)  
J:  Public  administration  (17%)  
C:  Construction  (100%)  
D:  Manufacturing  (100%)  
D:  Manufacturing  (51%)  
E:  Transportation,  communications,  
electric,  gas  and  sanitary  services  (13%)  
C:  Construction  (13%)  
I:  Services  (11%)  
F:  Wholesale  trade  (7%)  
A:  Agriculture,  forestry  and  fishing  (2%)  
G:  Retail  trade  (2%)  
J:  Public  administration  (1%)  
D:  Manufacturing  (63%)  
E:  Transportation,  communications,  
electric,  gas  and  sanitary  services  (25%)  
I:  Services  (12%)  
Musculoskeletal
Discomfort
The first red
flag is seeing records related to
1904.33  
Retention  and  updating  
minor discomfort
from ergonomic-related issues.
Despite the fact
that OSHA’s er   SIC divisions cited for improper recordkeeping practices, October 2011 to September 2012. SIC divisions are
Note.
gonomics rule
based
on the industry and services provided by each organization. The SIC divisions include a) agriculture, forestry
was rescinded,
and fishing; b) mining; c) construction; d) manufacturing; e) transportation, communications, electric, gas and sanimany recordkeeptary services; f) wholesale trade; g) retail trade; h) finance, insurance and real estate; i) services; j) public administraers continue to be
tion (OSHA, 2012a). More thorough industry information can be obtained by searching by the 2-, 3- or 4-digit SIC
confused about
code. Total percentage is rounded to the nearest 1%.
whether a musculoskeletal disorder or discomfort
is to be recorded. Ergonomics-related cases, in- and other ergonomic-related symptoms, as any
cluding musculoskeletal discomfort, are only to be other reported incident since the symptoms experecorded if certain circumstances apply to the in- rienced may be indicative of an injury or illness.
cident. OSHA wants employers to address all reEach incident must be fully evaluated to deterported musculoskeletal disorders, including pain mine whether it is a recordable case. According to
www.asse.org AUGUST 2013 ProfessionalSafety 31
Figure 4
Recordkeeping-Related
Citations Issued to Organizations
300  
258  
No.  of  cita�ons  
250  
200  
150  
100  
58  
50  
0  
51  
7  
1  
6  
1  
8  
8  
1904.4   1904.5   1904.6   1904.7   1904.8   1904.9   1904.10   1904.32   1904.33  
OSHA  recordkeeping  standard  
Note. This figure illustrates the number of citations issued by Federal OSHA between
October 2011 and September 2012 and the applicable OSHA recordkeeping standard for all
SIC Divisions. OSHA standards 1904.32, 1904.4 and 1904.7 have the highest occurrence of
issued citations.
Figure 5
Cost of Issued Citations
Related to Recordkeeping
Total  cost  of  issued  cita�onsa  
$80,000  
$70,000  
$60,000  
$64,990  
$71,814  
that there are between 5 and 30 million
workers in the U.S. who are exposed to
noise levels at work that put them at risk
of hearing loss” (CDC/NIOSH, 2011).
Omitting hearing-related illnesses from
records or recording them incorrectly
may suggest to the inspector that other
cases are also being recorded incorrectly.
Another red flag is when a significant
noise ha …
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