Changes to OSHA’s Recordkeeping Standard

Changes to OSHA’s Recordkeeping Standard

Changes to OSHA’s Recordkeeping Standard

The Occupational Health & Safety Administration (OSHA) is kicking off 2015 with updates to the Recordkeeping Standard. Although the requirements are few and some may be exempt from specific components of the standard, it is important to know how the changes will impact your practice. In order to understand how these changes will apply, let’s take a look at the basics of this standard and review the most frequently asked questions.

Since OSHA’s inception, employers have been required to report work-related fatalities to OSHA within eight hours of discovery of death. Other reporting requirements included notifying OSHA when three or more workers are hospitalized due to work-related injuries or illnesses. The updated standard that became effective January 1, 2015 for all states under the Federal OSHA jurisdiction retained the existing requirement of reporting all work-related deaths within eight hours. In addition, all in-patient hospitalizations, amputations, and losses of an eye have to be reported within twenty-four hours of finding out about the incident and only if they occur within twenty-four hours of the work-related incident. Also noteworthy is that only fatalities occurring within 30 days of the work-related incident must be reported to OSHA.

In what ways can employers report?

OSHA now provides three options to meet notification requirements.

  1. Call your nearest OSHA area office during normal business hours.
  2. Call OSHA’s twenty-four hour hotline at 1-800-321-6742 (OSHA).
  3. Report online at OSHA.gov.

Who is exempt and what does exemption mean?

What this means is that healthcare employers are exempt from maintaining the OSHA 300 log unless they are specifically asked by OSHA, the Bureau of Labor Statistics (BLS), or a state agency operating under the authority of OSHA or the BLS. This exemption does not mean; however, that healthcare entities do not have to comply with the reporting of fatalities, in-patient hospitalizations, amputations and losses of an eye, even when exempt from routinely keeping OSHA 300 logs. A few OSHA state plans have adopted this update into the state rules and effective dates of implementation have been posted. We encourage you to watch for changes if you are operating under a state OSHA plan by visiting OSHA.gov here: http://1.usa.gov/1F4hemX. As always, the expectation is that more stringent ruling will occur in many state OSHA programs. These could then require employers to submit additional documentation about illnesses and injuries and submit a report within a timelier manner.

How does this update apply to state OSHA programs?

Some employers in the U.S. are required to prepare and maintain records of serious occupational injuries and illnesses using the OSHA 300 Log; however, there are two classes of employers that are partially exempt from routinely keeping these injury and illness records. The two classes include employers with ten or fewer employees and employers in certain low-hazard industries. The January 2015 updated list of partially exempt industries show that healthcare entities did remain on the list.

  1. MedClean has the OSHA 300 log available in the OSHA tool kit. If you are already a client you can log in medcleansolutions.com to view the OSHA 300 log.

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