Recordkeeping Mistakes Part 1
Are you maintaining records of work-related injury and illness? OSHA’s regulation 29 CFR 1904 requires employers with more than 10 employees, unless exempt, to record, report, and post illnesses and injuries that occur on job sites. As OSHA lawyers, we represent employers who’ve cited for failure to maintain injury and illness records. Noncompliance puts you at risk for citations. We’ll discuss some areas you could be making recordkeeping mistakes. In Part 2, we’ll discuss more common mistakes.
The first step in recordkeeping is to have the correct forms on hand. Keep separate logs for each site. Use Form 300 to log the specifics of workplace incidents. Use Form 300A as an annual summary of work-related injuries and illnesses and post it in your workplace between February 1st and April 30th. Form 301 is an injury and illness incident report. Keep Forms 300 and 300A for five years.
Reporting and Recording
All work-related injuries and illnesses are reportable, but do you know what’s recordable? Do not record an observational or diagnostic doctor visit. First aid or medical prescriptions given during these types of appointments aren’t recordable. The first aid list is extensive, so be sure to check if a treatment qualifies as first aid before recording. Report and record the following work-related incidents:
- Losing consciousness
- Days away from work
- Restricted work activity or job transfer
- Medical treatment (excluding first aid)
There are additional criteria that must be recorded if diagnosed by a medical professional. If the case involves the following you should record it:
- Cancer or an irreversible disease
- Bone injuries
- Hearing tests and eardrum punctures
- Contaminated Needlestick injuries or cuts
- Tuberculosis infections
Disclaimer: The information contained in this article is for general educational information only. This information does not constitute legal advice, is not intended to constitute legal advice, nor should it be relied upon as legal advice for your specific factual pattern or situation.