OSHA RECORDKEEPING

REQUIREMENTS
PUBH 3310
September 10, 2012

Objectives
This presentation is intended to familiarize
students with OSHA recordkeeping
requirements. Students should:
Know about the OSHA Poster (where to post, State
requirements, etc.)
Be able to calculate basic injury and illness rates
Know how Utah injury and illness statistics compare with the
rest of the U.S.

Recognize criteria for a recordable injury or illness

Be familiar with OSHA accident and illness
recordkeeping forms (300, 300A, 301)
Know about other OSHA recordkeeping requirements
2

Outline

OSHA poster(s)
Reporting
Recordkeeping
Rates
Utah and Federal recordkeeping
requirements
OSHA recordkeeping forms
3

Introduction
Paragraph (c) of the 1970 OSH Act specifies
employee notification and recordkeeping for
accidents, injuries, and hazardous exposures:
Notices must be posted to inform employees of
their protections and obligations
Employers must maintain accurate records, make
periodic reports on deaths, injuries and illnesses
Records must be kept of exposures to potentially
toxic materials or harmful physical agents.
Employees or their representatives must have
access to exposure records
Employees must be notified if they are exposed
at or above regulated levels

OSHA Poster
Employers must display a poster to inform
employees of their protections and
obligations (29 CFR 1903.2)
OSHA specifies the poster content, size (at least 8
x 11 inches) and typeface (at least 10 font)
The poster can be downloaded for printing from
http://www.osha.gov/Publications/poster.html
States may require a substitute poster. Utah's
poster can be downloaded from
http://laborcommission.utah.gov/media/pdfs/uosha
/pubs/UOSH%20poster
%2020Aug2012%20vLS.pdf

The
Federal
OSHA
poster

The Utah
OSH
poster

10

11

12

13

Reporting accidents and injuries

Federal OSHA
Employers must report to OSHA within 8 hours if
there is an accident which causes a fatality or
hospitalization of 3 or more employees.

Utah
Notification within 8 hours of a fatality or a
disabling, serious, or significant injury, or any
occupational disease incident.
Recordable injuries and illnesses reported to the
Industrial Commission within 7 days
Form #122 Employer's First Report of Injury,

http://laborcommission.utah.gov/media/pdfs/industrialaccidents/
forms/Form%20122.pdf
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Reporting accidents and injuries

OSHA inspectors follow up on reports
Investigate accidents
Worksites may be inspected
Citations may be issued

It is a serious offense to fail to notify or to

destroy evidence after a serious accident
http://www.rules.utah.gov/publicat/code/r614/r614001.htm#T5

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Accidents and Injury

Recordkeeping
Why recordkeeping is important
Accident and illness recordkeeping is a
critical part of an employer's safety and
health effort
Help prevent accidents/injuries in the future.
Helps identify problem areas
Better administration of company safety and
health programs
Workers are more likely to follow safe work
practices and report workplace hazards.
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Accidents and Injury

Recordkeeping
Why recordkeeping is important (cont.)
OSHA uses data to identify and focus on
injuries and illnesses in a particular area.
About 80,000 establishments each year report the
data directly to OSHA, which uses the information
as part of its site-specific inspection targeting
program.
The Bureau of Labor Statistics (BLS) also uses
injury and illness records as the source data for the
Annual Survey of Occupational Injuries and
Illnesses that shows safety and health trends
nationwide and industrywide.
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Accident and injury rate

Why recordkeeping is important (cont.)
Companies use accident and injury rates to
track their safety performance:
Over time, to show trends
With other firms, to show how they compare
with data available from the Bureau of Labor
Statistics

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Accident and injury rate

Fatalities are commonly reported as case
counts, rather than rates
Counts allow for comparisons over time within a
group, but it is difficult to make comparisons
between groups of different sizes
When fatality rates are reported, they usually are
based on deaths per 100,000 employees

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Fatalities
Total Transportation
Incidents

Assaults
and
violent
Acts

Contact
with
objects
and
equipment

Falls Exposure to
harmful
substances
or
environments

Fires and
explosions

Utah
2010

42

15

Utah
2009

48

27

U.S.
2010

4,690

1,857

832

738

646

414

191

U.S.
2009

4,340

1,682

788

734

617

390

113

There were fewer Utah fatalities in 2010, but we need rate information to know if
workers are more or less likely to die in Utah than other states.

Accident and injury rate

The Total Injury and Illness Rate
Also known as the Injury and Illness Incident Rate or
Injury Frequency Rate or Total Recordable Case Rate
Includes all recordable cases, with or without lost time
Rate calculations compensate for the size of the
workforce:

200,000 is the base for 100 full-time equivalent workers (40

hours/week for 50 weeks/year).

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2010 Injury/Illness Incident Rates

PRIVATE
TOTAL Manufacturing
INDUSTRY CASES

Construction

Utah

3.6

4.2

4.2

National

3.8

4.4

4.0

(Annual injuries and illnesses per 100 full-time workers. 2011 injury data
is not expected until late October, 2012.)
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Accident and injury rate

Restricted Work Rates
DART, Days of Activity Restriction or job Transfer
Only includes cases with lost time
Also known as LWDII, Lost Workday Injury and Illness
rate

(Cases with time away from work,

job transfer or restriction)

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2010 Days Activity Restriction or

job Transfer (DART)
PRIVATE
TOTAL Manufacturing
INDUSTRY CASES

Construction

Utah

1.4

1.9

1.4

National

1.9

2.4

2.1

(Annual injuries and illnesses per 100 full-time workers)

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Accident and injury rate

DART Example:
Workers of an establishment, including
temporary, and leased workers, worked
645,089 hours at the company
There were 22 injury and illness cases
involving days away and/or restricted work
activity and/or job transfer (from the OSHA
300 Log, total of column H plus column I)
The DART rate rate would be (22/645,089) x
(200,000) = 6.8
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Accident and injury rate

Days Away from Work Injury and Illness
(DAFWII) Case Rate
The DAFWII is similar to the DART, but:
It only involves cases involving time away from
work
It does not include cases involving job transfer
or restriction

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2009 Days Away from Work

Injury and Illness (DAFWII)
PRIVATE
TOTAL Manufacturing
INDUSTRY CASES

Construction

Utah

0.8

0.9

0.8

National

1.2

1.1

1.5

(Annual injuries and illnesses per 100 full-time workers)

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OSHA targets high-hazard

worksites
OSHA placed about 4000 employers on
notice due to their high injury and
illness rates (Sept. 2011)
These employers reported the highest "Days
Away from work, Restricted work or job Transfer
injury and illness" (DART) rate:
3000 manufacturers with 2009 DART rate 7.0
400 non-manufacturers with DART 14.0
300 nursing care facilities with DART 16.0
The national average was 1.8
http://www.osha.gov/pls/oshaweb/owadisp.show_document?
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p_table=NEWS_RELEASES&p_id=20646

Severity rate
Injury Severity Rate
While not as widely used, this rate can provide more
information about workplace safety
The calculation uses total days away from work,
rather than number of cases

For example, if one relied only on the DART, a firm with

a large number of minor injuries could look worse than a
firm having fewer yet much more serious injuries:
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Utah recordkeeping rules

Utah Occupational Safety and Health
regulations are found in the Utah
Administrative Code, State Rule R614-1,

http://www.rules.utah.gov/publicat/code/r614/r614001.htm#T8 .
The Federal recordkeeping rule is adopted by
reference
Injuries or illnesses must be entered on the form
as soon as practicable, but no later than 6 days
after learning of a reportable case
Supplemental information must be recorded on
OSHA Form 301 or equivalent within 6 days
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OSHA Requirements
Federal OSHA's recordkeeping
requirements are found in 29 CFR
1904.
Recordkeeping rules were changed in
2001-2003
Changes include new forms and simplified
recordkeeping
OSHA brochure:
http://www.osha.gov/Publications/osha3169.pdf31

OSHA Requirements
Recordkeeping
Reporting fatalities and catastrophes
Employers covered by OSHA must report any
workplace fatality or hospitalization of three or
more employees within 8 hours (Utah is more
stringent)
Unless requested, injury and illness records are not
needed for:
Employers with 10 or fewer employees
Business in a specified low-hazard retail, service,
finance, insurance, or real estate industry
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OSHA Requirements
Basic Recordkeeping Requirements
1. List injuries and illnesses and track days away
from work, restricted, or transferred on Form 300
2. Record supplementary information about
recordable cases on Form 301 (or use workers'
compensation insurance form)
3. Post Form 300A February 1 to April 30 of each
year to show totals
Refer to 29 CFR 1904, "Recording and Reporting
Occupational Injuries and Illnesses," for more
information,

http://www.osha.gov/pls/oshaweb/owadisp.show_documen
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t?p_table=STANDARDS&p_id=9632

Recordable injuries/illnesses
Recordable work-related injuries and
illnesses include:
1.
2.
3.
4.
5.
6.

death
loss of consciousness
days away from work
restricted work activity or job transfer
medical treatment beyond first aid
Work-related injuries and illnesses that are
significant or meet additional criteria as
specified

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Recordable injuries/illnesses
Recordable work
restrictions
Employee is kept
from doing routine
job functions the next
full work day that the
employee have been
scheduled to work
before the injury or
illness occurred.

Recordable medical
treatment
Managing and caring
for a patient for the
purpose of
combating disease
or disorder

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Recordable injuries/illnesses
Recordable
significant injury or
illness
Diagnosed by physician
or other licensed health
care professional
Cancer
Chronic irreversible
disease
Fractured or cracked
bone
Punctured eardrum

Recordable
additional criteria
Needlestick injury
Medical removal as
required for an OSHA
health standard
Positive skin test for
tuberculosis
Loss of hearing
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Non-Recordable injuries/illnesses
Not recordable medical treatment
Visits to a doctor or health care solely for
observation or counseling
Diagnostic procedures, including
administering prescription medications are
used solely for diagnostic purposes
Any procedure that can be labeled first aid.

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Non-Recordable injuries/illnesses
Not Recordable first aid
Non-prescription medications
at non-prescription strength
Tetanus immunizations
Cleaning, flushing, or soaking
wounds on the skin surface
Using wound coverings
Hot or cold therapy
Non-rigid means of support,
such as elastic bandages
Temporary immobilization
devices while transporting a
victim

Drilling a fingernail or
toenail to relieve
pressure, or draining
fluids from blisters
Using eye patches
Removing foreign bodies
not embedded in the eye
Removing splinters from
areas other than the eye
Using finger guards
Massages
Drinking fluids to relieve
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heat stress

Worker privacy
Enter privacy case instead of the
employee name on the recordkeeping
form for:
Injury or illness to an intimate body part or to the
reproductive system
Injury or illness resulting from a sexual assault
Mental illness,
HIV infection, hepatitis, or tuberculosis
Needlestick injury or cut from a sharp object that is
contaminated with blood or other potentially
infectious material
Other illnesses, upon employee request
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OSHA Recordkeeping Forms

OSHA Form 300, Log of Work-Related Injuries
and Illnesses
Simplified and reformatted to fit legal size paper.

OSHA Form 301, Injury and Illness Incident

Report
Includes more data about how the injury or illness
occurred.

OSHA From 300A, Summary of Work-Related

Injuries and Illnesses
Separate form created to make it easier to calculate
incidence rates

Download pdf or Excel forms from

http://www.osha.gov/recordkeeping/RKforms.html
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OSHA Form 300

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OSHA Form 300A

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Optional worksheet

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OSHA FORM 301

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Other OSHA Recordkeeping

Other OSHA Recordkeeping
Requirements
Employers must maintain records when toxic
materials or harmful physical agents are required
to be monitored or measured.
Maintain records for at least 30 years:
Employee exposure records
A record of the agent (where and when it was
used)
Medical records (duration of employment plus
30 years)
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Other OSHA Recordkeeping

Other OSHA Recordkeeping
Requirements (cont.)
Employees, their representative, and OSHA must
be granted access to this information upon
request.
Employers may restrict access to trade secrets,
but they are required to reveal chemical
information to medical personnel upon request.
Employers must notify NIOSH if they are going out
of business and the records may be destroyed.
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Other OSHA Recordkeeping

Specific OSHA standards commonly
impose recordkeeping requirements on
the employer. These records include:
Material Safety Data Sheets
Training records
Workplace evaluations
etc.
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