Did you know that you must document your efforts to comply with OSHA regulations? Various regulations specify requirements for collecting, keeping, and providing certain types of occupational health and safety information and records.
Documentation of your safety compliance efforts should include (but is not limited to):
- Safety orientations/training records
- Safety meetings minutes
- Written safety policies and procedures
- Hazard identification and corrective
- Equipment maintenance and inspection records
- Employee medical and exposure records
- Incident report
- Injury and illness records
- Accident/Incident investigations reports
- OSHA citations and abatement actions
You must retain safety records for a specific amount of time.
Retention requirements generally range from 1 to 5 years. Check the specific regulations that apply to your industry, but as a best practice, retain safety and training records for 5 years. Note that some regulations have separate retention requirements. For example, employee medical records, including material safety data sheets (MSDS), must be kept for the length of employment plus 30 years.
Safety Records Management System
Organizing your safety records can be a daunting task. A well-organized safety records management system will be a workable filing system, whether electronic or otherwise, that can save time, effort, and money in the future. To create a workable records management system, determine if it will be an electronic or a traditional hard copy system. Then, decide the main categories for your filing system followed by sub-categories. Sub-categories may be further divided, e.g., by year, as needed. Create file folders (electronic or hard copy) for each category and sub-category. Using an electronic filing system, the sub-categories are nested under the main category folder. For example, for the main category of “Employee Training” as listed above, would have sub-categories that may include “New Hire Safety Orientation”, “Jobsite Project Induction”, “Respiratory Protection”, “Fire Safety & Extinguisher Use” etc.
You must provide employees access to safety records.
Employees have a right to information and records about hazardous chemicals in the workplace (MSDS), hazard exposure monitoring, and their own safety, personnel, and medical records. You must provide employees access to safety records within a reasonable timeframe (usually 7 days) and must notify employees when monitoring indicates that they have been exposed to a hazard. Employees also have the responsibility to report all workplace hazards, illnesses, injuries, accidents, and near misses so they can be evaluated and prevented in the future.
You must track and report workplace injuries and illnesses.
There are two exceptions to these recordkeeping requirements: If you have ten or fewer employees, you are not required to keep these records unless you are asked in writing to do so by OSHA or the Bureau of Labor Statistics (BLS). Similarly, if you operate in a low-hazard industry, you have to keep these records only if OSHA or the BLS asks you specifically to do so. (Click herefor Non-Mandatory Appendix A to Subpart B – Partially Exempt Industries.)
The regulations provide two forms for recording this information, OSHA Forms 300 (the Log of Work-Related Injuries and Illnesses) and 300A (the Summary of Work-Related Injuries and Illnesses). In addition, you must maintain a supplementary record for each recordable injury or illness on Form 301 (Injury and Illness Incident Report), or an equivalent form. Some state workers’ compensation, insurance, or other reports may be acceptable substitutes. To be considered an equivalent form, any substitute must contain all the information asked for on this form.
Click here for Regulatory Detail – 29 CFR 1904 Subpart B Injury and Illness Recording and Reporting.
What injuries/illnesses must be recorded on the OSHA 300 Log?
All new cases of work-related injuries and illnesses must be recorded on the OSHA 300 Log that involve:
- Restricted work or transfer to another job.
- Days away from work.
- Medical treatment beyond first aid.
- Loss of consciousness.
- A significant injury or illness that has been diagnosed by a physician or other licensed health care professional.
You must enter each recordable injury and illness on the OSHA 300 Log and 301 Incident Report within seven calendar day of receiving information that a recordable injury or illness has occurred.
What is the 300A summary?
Form 300A is intended to summarize the employer’s yearly totals for illnesses and injuries and is taken from the information recorded on the OSHA 300 Log. Specifically, it requires that you calculate the total number of cases with days away from work, cases with job transfers or restrictions, any other recordable cases, and deaths. In addition, you must identify the total number of days of job restrictions or transfers and days away from work. Finally, you must report what types of injuries and illnesses you experienced, including the total number of injuries, skin disorders, respiratory conditions, poisonings, and all other illnesses.
Where and when do we post the 300A summary?
You must post the annual summary no later than February 1 each year, and it must remain posted until April 30. You must post a copy of your annual 300A summary in each establishment in a conspicuous place or places where notices to employees are customarily posted, such as in employee break areas or locker rooms. You also must ensure that the posted annual summary is not altered, defaced or covered by other material. In addition, an executive must certify that the OSHA 300 Log has been examined and that the annual summary is believed to be correct and complete. The certifying executive can be either the owner or an officer of the organization, the highest ranking executive at the establishment, or the supervisor of that highest-ranking executive.
All injury reports must be maintained for at least 5 years, plus the current year’s report. (Five years is the minimum retention time.)
You must report fatalities and serious injuries to OSHA.
You must report to OSHA all work-related fatalities within 8 hours, and any work-related hospitalization, amputation, and loss of an eye within 24 hours. This requirement is for all employers — even those in Partially Exempt Industries mentioned above.
Employers have 3 options for reporting the event by:
- Calling, or visiting, the nearest area office during normal business hours;
- Calling OSHA’s free and confidential number at 800-321-OSHA (6742); or
- Using the new online form, which will soon be available on osha.gov/report_online.
Only fatalities occurring within 30 days of the work-related incident must be reported to OSHA. Inpatient hospitalization, amputation, or loss of an eye must be reported to OSHA only if they occur within 24 hours of the work-related incident. Previously, work-related fatalities and hospitalization of three or more employees required reporting.
For a detailed discussion of OSHA’s recordkeeping requirements, click here to refer to the OSHA Recordkeeping Handbook.
You must post certain information in the workplace.
Many of the employment laws administered by the U.S. Department of Labor (DOL) require you to post notices in the workplace (see table below). The Department provides electronic copies of the required posters and some of the posters are available in languages other than English.
States and local governments may also have posting requirements. You should contact the appropriate state or local agency if you need additional state-specific information.
In addition, you must post any current citations that OSHA officers have issued to you, and any petitions that you have filed with OSHA for modification or abatement.
As mentioned above, if you are covered by OSHA’s recordkeeping requirements described above, you must post an annual summary of occupational illnesses and injuries.
Click here for Regulatory Detail – 29 CFR §1903.2 Posting of notice; availability of the Act, regulations and applicable standards
Federal Posting Requirements
Click here for a summary of Federal posting requirements.