The Importance of Recordkeeping
The Importance of Recordkeeping
Mylene Kellerman, MS, COHC, USF SafetyFlorida Safety and Health Supervisor
While OSHA has not changed its recordkeeping requirements, it has increased its enforcement of them.
On October 1, 2009, OSHA initiated a national emphasis program on recordkeeping in order to assess the accuracy of injury and illness data recorded by employers. "Accurate and honest recordkeeping is vitally important to workers' health and safety," said acting Assistant Secretary of Labor for OSHA Jordan Barab. "This information is not only used by OSHA to determine which workplaces to inspect, but it is an important tool employers and workers can use to identify health and safety problems in their workplaces."
Under this emphasis program, OSHA will continue to inspect the occupational injury and illness records of selected industries with high injury and illness rates and appropriately enforce regulatory requirements when they find employers under-recording injuries and illnesses.
Here are some tips from USF SafetyFlorida that can help you with your recordkeeping:
1. When injuries and illnesses occur in the workplace, key risk management, safety and human resources personnel should meet to discuss whether the particular injury or illness is work-related and meets OSHA’s general recording criteria. They should also ensure that log entries are accurately completed. This is recommended since recordkeeping rules can be complicated and quite challenging at times to implement.
2. OSHA requires employers to complete data entry on the recordkeeping 300 log and the associated 301 incident report (or appropriate equivalent) within seven calendar days of receiving information that a recordable injury or illness has occurred. Employers should not be hasty to log the incident but instead do a thorough investigation, gather all of the facts, and then complete the required forms, if required.
3. Have a policy in place to ensure the injury and illness log is reviewed and updated every month to accurately reflect changes in the status of the injured/ill employee(s).
4. Keep abreast with OSHA’s letters of interpretations on record-keeping. These are available on OSHA’s website - www.osha.gov -- and employers are encouraged to routinely review and incorporate the guidance into their record-keeping policies and procedures.
5. Employers are encouraged to review safety incentive programs to make sure the programs do not dissuade employees from reporting injuries and illnesses. Certain safety incentives, disciplinary policies or other programs may at times keep employees from reporting incidents. Examine the extent to which the program or policy may discourage reporting and make appropriate changes.
6. An injury may be OSHA recordable, but not compensable under workers’ compensation, and vice versa. Make sure there is proper documentation available to explain why an injury was compensable, but not recordable. It is advisable to periodically compare workers’ compensation claims against the OSHA 300 log to identify any undocumented differences.
7. When injuries and illnesses occur in the workplace, document the steps taken and efforts made to address and prevent recurrence of the hazards. Document thoroughly what was done to address the underlying hazard that may have caused an injury or illness.
Record-keeping is very important to OSHA and the nationwide emphasis program will steer the agency to vigorously enforce this rule. USF SafetyFlorida encourages you to take the time to review your injury and illness logs and your record-keeping procedures to ensure they are fully compliant with OSHA’s record-keeping rule and fully prepared for an OSHA inspection.
Remember to post the reviewed, completed and certified OSHA 300A summary log of 2009 in a conspicuous place or places where notices to employees are customarily posted. The log must be posted from February 1 through April 30, 2010. And finally, to help you with your recordkeeping, USF SafetyFlorida provides RecordKeeper, a free and secure online OSHA recordkeeping system. Filling in the data one time automatically updates each of your OSHA recordkeeping forms.