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Safety Management Insights

Keeping Compliant with OSHA Record Keeping Changes

Posted by Don Brown on Nov 18, 2015 8:30:00 AM

record-keepingIt’s been nearly a year since the Occupational Safety and Health Administration (OSHA) implemented its newest record keeping rules, which brought about a couple of important changes. Are you staying compliant? The alterations weren’t massive, but they might bring your company under greater scrutiny. To make sure you’re keeping up with OSHA’s ever-changing guidelines, read on to get a better idea of your company’s requirements, as well some of the common mistakes businesses make in reporting.

Exempt Industries

One of the biggest changes was an update to the list of low-risk industries exempt from routine record keeping requirements. The old list was based on the Standard Industrial Classification system, which only took into account Bureau of Labor Statistics (BLS) data from 1996 to 1998. It’s now based on the North American Industry Classification System, as well as more recent BLS data from 2007 to 2009. Some previously scrutinized industries are now exempt, while a few growing industries are under a more watchful eye. OSHA’s website has more info on the specifics; make sure you know where you stand.

New Reporting Requirements

The new rules also expanded the list of severe work-related injuries and illnesses that all employers must report to OSHA. Employers are still required to report fatalities within eight hours, and they must report all inpatient hospitalizations, amputations and losses of eyes within 24 hours. If those injuries occur more than 24 hours after the related incident, however, they do not need to be immediately reported.

Form 301

OSHA Log 300 has long been a requirement for covered companies. Most employers maintain the log on a calendar-year cycle, record incidents within seven days of occurrence, and retain each log for five calendar years. Each Form 300 contains information related to several employees and incidents.

The 2015 rule change added Form 301 to the list of requirements. This supplementary form provides more detailed information on a single case, including the events leading to the incident, body parts affected, and hazardous substances involved. Employers are allowed to use other documents that include the same information, however, as long as they include all of the relevant details of the OSHA form. State workers’ compensation reports, insurance claim reports and in-house incident report forms may also suffice.

Common Mistakes

Still worried about your own compliance with the new rule? The changes took effect last January, but it’s easy to lose track of all of OSHA’s updates. Here are a few common pitfalls you’ll want to avoid.

  • Failure to maintain your logs. With a few exceptions, most companies with more than 10 employees must log incidents with forms 300, 300A and 301.
  • Not using unique case numbers. You generate your own case numbers when filling out your forms, but you’ve got to make sure they’re unique. Redundancy will lead to a lot of headaches for both your team and OSHA auditors.
  • Incorrect certifying personnel. The 300A Summary must be signed by the highest-ranking person at the physical work site where the incidents occurred. This might not be the same person who fills out the form.
  • Recording every incident. Not every injury or illness falls under OSHA’s record keeping requirements, so don’t make your logs look worse than necessary. A form full of minor, unnecessarily recorded incidents makes your workers seem less safe than they really are. Under-reporting is a citable offense, but over-reporting is sloppy and impractical.

Keeping Track

With all of these rules to remember—and with so much data to collect—it often seems impossible to keep track of every form. Fortunately, BasicSafe offers safety management software that allows your company to easily store and share your safety documents. Keeping this information at your fingertips will improve your regulatory compliance, and it can even save lives. Contact us today to learn how we can help you.

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