Critical OSHA standards TOP STANDARDS 2019
29
OSHA Injury / Illness Recordkeeping and Reporting 29 CFR 1904
Scope
Under the rule, establishments with 250 or more
employees that are currently required to keep OSHA
injury and illness records are also required to elec-
tronically submit their
Forms 300A, 300,
and 301.
Smaller establish-
ments (with 20-249
employees) that are
classified in certain
industries with histori-
cally high injury and
illness rates are also
required to submit the 300A form (Summary of Work-
Related Injuries and Illnesses).
The deadline for submitting 300A data to OSHA for
Calendar Year 2017 was July 1, 2018. OSHA contin-
ued to collect CY17 forms until December 31, but sub-
missions received after July 1 were flagged as “late.”
OSHA will begin collection of CY18 Form 300A
data on January 2, 2019. The deadline for submitting
these data is March 2, 2019. Note this is much earlier
than the past two years.
In July, OSHA published a notice of proposed
rulemaking to amend the recordkeeping regulation
to remove the requirements for submission of the
Forms 300 and 301. That comment period closed on
29 CFR 1910.146: OSHA Confined Space Standard – General Industry
Date adopted
January 14, 1993
Back story
In January, 1993, OSHA promulgated a standard
that requires employers to protect employees assigned
to enter Permit-Required Confined Spaces from
these hazards. Subsequent revisions clarified several
provisions of the rule and revised the "Atmospheric
Monitoring" section of non-mandatory Appendix E,
"Sewer System Entry."
Scope
The standard applies to all general industry places
of employment, including agricultural services, manu-
facturing, transportation and utilities, wholesale trade,
food stores, hotels and other lodging, health services,
museums, botanical gardens and zoos.
Confined spaces are large enough for workers to
enter and perform certain jobs but have limited or
restricted means for entry or exit and are not designed
for continuous occupancy. Confined spaces include,
but are not limited to, tanks, vessels, silos, storage bins,
hoppers, vaults, pits, manholes, tunnels, equipment
housings, ductwork, pipelines, etc.
“Permit-required confined spaces" have the potential
to contain a hazardous atmosphere; contain material
that has the potential to engulf an entrant; or have
walls that converge inward or floors that slope down-
ward and taper into a smaller area which could trap or
asphyxiate an entrant.
Key hazards
A 1998 incident at Union Carbide Corporation's
Taft/Star Manufacturing Plant in Hahnville, Louisiana
vividly demonstrated the potential dangers of confined
01p29Standards_recordkeeping_confspaceGen.indd 29
September 2018. The deadline for submitting these two
forms for CY17 was July 1.
OSHA will not enforce the deadline for these two
forms, without further notice, while the rulemaking is
underway.
Form 300 is a log of work-related injuries and ill-
nesses that includes the injured or ill employee’s
name; date of injury or illness; the location of the
incident; a description of body parts injured and the
object/substance that caused the injury; whether or
not the injury caused lost or restricted time or a job
transfer; the number of days lost, restricted or involv-
ing a job transfer; and whether the incident resulted in
an injury or one of six illness types.
Form 301 is a detailed report of the injury or illness,
consisting of 18 questions.
Recordkeeping requirements
Many employers with more than 10 employees
are required to keep a record of serious work-related
injuries and illnesses. (Certain low-risk industries are
exempted.) Minor injuries requiring first aid only do
not need to be recorded.
Maintaining and posting records
Records must be maintained at the worksite for at
least five years. Each February through April, employ-
ers must post a summary of the injuries and illnesses
spaces. One worker was killed and
another seriously injured when they
were asphyxiated by nitrogen. The
incident occurred inside a tem-
porary enclosure the workers had
erected over the end of large open
gas pipe, where they were conduct-
ing a black light inspection. The
workers were not aware that the
pipe was being purged with nitro-
gen, creating an oxygen-deficient atmosphere.
Key provisions
Confined spaces that contain or have the potential to
contain a serious atmospheric hazard should be classi-
fied as permit-required confined spaces, tested prior to
entry and continually monitored.
• If a workplace contains permit spaces, the
employer must inform exposed employees of their
existence, location and the hazards they pose. This can
be done by posting danger signs such as “DANGER—
PERMIT-REQUIRED CONFINED SPACE—
AUTHORIZED ENTRANTS ONLY” or using an
equally effective means.
• Any employer who allows employee entry into a
permit space must develop and implement a written
program to prevent unauthorized entry; identify and
evaluate permit space hazards before allowing employ-
ee entry; test atmospheric conditions in the permit
space before entry operations and monitor the space
during entry and establish and implement the means,
procedures and practices to eliminate or control haz-
ards necessary for safe permit space entry operations.
• Controlling hazards can include: specifying accept-
able entry conditions; isolating the permit space; provid-
ing barriers; verifying acceptable entry conditions; and
recorded the previous year.
Electronic submission of records
The Injury Tracking Application (ITA) is accessible
from the OSHA’s ITA launch page, where you can pro-
vide the agency your OSHA Form 300A information.
Severe injury reporting
Employers must report any worker fatality within 8
hours and any amputation, loss of an eye, or hospital-
ization of a worker within 24 hours.
When is an injury or illness considered
work-related?
According to OSHA, an injury or illness is consid-
ered work related if an event or exposure in the work
environment caused or contributed to the condition
or significantly aggravated a preexisting condition.
Work-relatedness is presumed for injuries and illnesses
resulting from events or exposures occurring in the
workplace, unless an exception specifically applies.
See 29 CFR Part 1904.5(b)(2) for the exceptions. The
work environment includes the establishment and other
locations where one or more employees are working or
are present as a condition of their employment. See 29
CFR Part 1904.5(b)(1).
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purging, making inert, flushing or ventilat-
ing the permit space. In addition to person-
al protective equipment, other equipment
that employees may require for safe entry
into a permit space includes: testing, moni-
toring, ventilating, communications and
lighting equipment; barriers and shields;
ladders; and retrieval devices.
• If hazardous conditions are detected
during entry, employees must immedi-
ately leave the space. The employer must evaluate the
space to determine the cause of the hazardous atmo-
sphere and modify the program as necessary.
• Before the initial work assignment begins, the
employer must provide proper training for all workers
who are required to work in permit spaces
• Employers must provide rescue service personnel
with personal protective and rescue equipment, includ-
ing respirators, and training in how to use it. Rescue
service personnel also must receive the authorized
entrants training and be trained to perform assigned
rescue duties and be trained in first aid and CPR.
• Authorized entrants who enter a permit space must
wear a chest or full body harness with a retrieval line
attached to the center of their backs near shoulder level
or above their heads.
ISHN JANUARY 2019
Compliance assistance
“Permit-Required Confined Spaces in
General Industry” – an OSHA Quick Card.
OSHA’s “Confined or Enclosed Spaces
and Other Dangerous Atmospheres.”
www.ishn.com
OSHA’s “Confined Spaces Advisor.”
Go to www.ishn.com/topics for
more articles on this and other topics.
12/18/18 11:30 AM
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