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Revised Record Keeping Rule Finalized

OSHA's existing record keeping requirements have been in place since 1971 and have log been criticized as complicated and confusing. The revised rule is designed to produce better information about occupational injuries and illnesses while simplifying the overall record keeping system for employers. The rule will also better protect employees' privacy. Additionally, recently passed legislation requires OSHA to address and make provisions for the recording of needlestick/sharps injuries.

The final rule becomes effective on January 1, 2002. OSHA published the rule in the Federal Register on January 19, 2001 to give employers ample time to learn the new requirements and revise computer systems they may be using for recordkeeping. Like the former rule, employers with 10 or fewer employees are exempt from most requirements of the new rule, except in the case of reporting the hospitalization of three or more employees or a fatality to OSHA within eight hours.

The revised recordkeeping standard still requires employers to track, record and report workplace injuries and illnesses, but makes it easier for employers to successfully meet the requirements of this standard.

Some notable changes in the revised record keeping rule:

  • Maintain three recordkeeping forms
    1. OSHA 300 form: log for work-related injuries and illnesses; simplified and printed on smaller, legal-sized paper
    2. OSHA 300A form: summary of work-related injuries and illnesses; a separate form updated to make it easier to calculate incidence rates
    3. OSHA 301 form: injury and illness incident report
  • OSHA 301 incident report form, or an equivalent form, must be completed for each entry on the OSHA 300 log.
  • One set of criteria will be used to record both work-related injuries and illnesses.
  • New definitions of medical treatment, first aid and restricted work to simplify recording decisions.
  • A significant degree of aggravation must exist before a pre-existing injury or illness becomes recordable.
  • Recording of a light duty or restricted case is clarified.
  • All needlestick and sharps injuries must be recorded.
  • All standard threshold shift (STS) hearing loss must be recorded in the separate column of the OSHA 300 log.
  • All Musculoskeletal Disorders must be recorded in the separate column of the OSHA 300 log.
  • All cases of tuberculosis transmission must be recorded.
  • Eliminate the term "lost workdays" and replace with "days away" or "days restricted"; days counted will rely on calendar days (including weekends and holidays not just workdays).
  • Employers must establish a procedure for employees to report injuries and illnesses and tell them how to report.
  • Protect employee privacy by not entering an individual's name on Form 300 for certain types of injuries/illnesses, not describing the nature of sensitive injuries that may reveal the identity of the individual, only giving access to OSHA 301 forms that contain no personal identifiers, and removing employees' names before providing the data to persons not provided access rights under this rule.
  • Annual summary (OSHA form 300A) must be posted for three months from February 1 to April 30 of each year along with certification by a company executive.