Are you in compliance with OSHA's record keeping requirements with regard to
work place injuries? If the phone calls that I receive are any indication, many
employers, especially small ones, are unaware of OSHA's requirements for
recording and reporting occupational injuries. This article will provide a
synopsis of those requirements.
OSHA's recordkeeping requirements are found at 29 CFR 1904. Employers of less
than 10 employees or those engaged primarily in retail, trade, finance,
insurance, real estate, or services are exempt from these requirements except
for a duty to report fatalities or in-patient treatment of three or more
OSHA requires that each covered employer keep: (1) a log and summary of
occupational injuries; (2) a supplementary record; (3) an annual summary; and
(4) orally report fatalities and certain injuries to OSHA. The log and summary
must be kept on OSHA Form 200 or its equivalent. All recordable injuries must be
entered in the log as soon as practicable, but no later than six working days
after receiving information that a recordable injury has occurred.
Recordable is defined as cases involving: fatalities (regardless of the time
between the injury and death); lost work days; transfers to another job or
termination of employment; or require medical treatment (other than first aid);
or loss of consciousness; or restriction of work or motion. Medical treatment is
defined as treatment under the orders of a physician administered by a physician
or other registered medical personnel. The definition of lost work days does not
include the day of the injury.
The employer must also keep supplementary information for all recordable
injuries. OSHA Form 101 or other equivalent forms used for insurance claims
reporting or workers' compensation are also acceptable alternatives if they
contain the same information that is on the OSHA Form 101.
The employer must also maintain an annual summary of all recordable injuries.
These summaries must be kept on a calendar basis. The summary must be posted at
the workplace and must include the year's total from the OSHA 200 log. It must
include the calendar year covered, the name and address of the establishment,
and a certifying signature and date. Even if no injuries occurred in the
previous year, zeros must be entered into the totals line.
Some recordable workplace injuries are also reportable. They must be reported
orally to OSHA within eight hours of the employer becoming aware...