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
- 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.