Osha Recordkeeping Requirements

The Occupational Safety and Health Administration (OSHA) was behind a 1970 law that requires certain employers to prepare and maintain records of occupational injuries and illnesses. This form - the Log 200 Form - must be posted during the month of February every year. This article describes OSHA recordkeeping requirements and the Log 200 Form.

The U.S. Department of Labor's Bureau of Labor Statistics is responsible for administering the recordkeeping system established by 1970 Act. It and the recordkeeping regulations in 29 CFR 1904 provide specific recording and reporting requirements, which constitute the recording system's framework.

The OSHA Act applies to nearly all employers in the private sector. It concerns work performed in a workplace in a state, the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, American Samoa, Guam, the Trust Territory of the Pacific Islands, Wake Island, Outer Continental Shelf Lands (defined in the Outer Continental Shelf Lands Act), Johnson Island, and the Canal Zone.

Two forms are used for OSHA recordkeeping. One form, the OSHA No. 200, serves two purposes:

• The Log of Occupational Injuries and Illnesses is used to record the occurrence, extent, and outcome of cases during the year, and to summarize the log at the end of the year to satisfy employer posting obligations.
• The Supplementary Record of Occupational Injuries and Illnesses, OSHA No. 101, provides additional information on each of the cases that have been recorded on the log.

The Log of Occupational Injuries and Illnesses, OSHA No. 200 is used for recording and classifying recordable occupational injuries and illnesses, and for noting the extent and outcome of each case.

The log shows when the occupational injury or illness occurred, to whom it occurred, what the injured person's regular job was at the time of injury or illness exposure, the department in which the person was employed, the kind of injury or illness, how much time was lost, whether the case resulted in a fatality, and so forth.

The log consists of three parts:

1. A descriptive section that identifies the employee and briefly describes the injury or illness
2. A section covering the extent of the injuries recorded
3. A section on the type and extent of illness

In addition to keeping the log on a calendar-year basis, employers are required to update this form to reflect changes that occur in recorded cases after the end of the year.

Maintaining or updating the log is different from record retention. Although all OSHA injury and illness records must be retained, only the log must be maintained by the employer. If, during the five-year retention period, there is a change in the extent or outcome of an injury or illness that affects an entry on a previous year's log, then the first entry should be lined out and a corrected entry made on that log.

New entries should be made for newly discovered and previously unrecorded cases and for cases that initially weren't recorded but were found to be recordable after the end of the year in which it occurred. The entire entry should be lined out for recorded cases that are later found nonrecordable. Log totals should also be modified to reflect these changes.

Employers are required to record information about every occupational death; every nonfatal occupational illness; and nonfatal occupational injuries that involve one or more of the following: loss of consciousness, restriction of work or motion, transfer to another job, or medical treatment (other than first aid). This definition provides sufficient guidance for analyzing the vast majority of cases under the OSHA recordkeeping system.

The decision-making process consists of five steps:

1. Determine whether a case occurred -- that is, whether there was a death, illness, or an injury.
2. Establish that the case was work related -- that it resulted from an event or exposure in the work environment.
3. Decide whether the case is an injury or an illness.
4. If the case is an illness, record it and check the appropriate illness category on the log.
5. If the case is an injury, decide if it is recordable based on the existence of medical treatment, loss of consciousness, restriction of work or motion, or transfer to another job.

The following categories are generally considered to be medical treatment. Work-related injuries for which these types of treatment was provided are almost always recordable:

• Treatment of INFECTION
• Application of ANTISEPTICS during second or subsequent visit to medical personnel
• Treatment of SECOND- OR THIRD-DEGREE BURN(S)
• Application of SUTURES (stitches)
• Application of BUTTERFLY ADHESIVE DRESSING(S) or STERI-STRIP(S) in lieu of sutures
• Removal of FOREIGN BODIES IMBEDDED IN EYE
• Removal of FOREIGN BODIES FROM WOUND -- if procedure is complicated because of depth of embedment, size, or location
• Use of PRESCRIPTION MEDICATIONS (except a single dose administered on a first visit for minor injury or discomfort)
• Use of hot or cold COMPRESS(ES) during second or subsequent visit to medical personnel
• CUTTING AWAY OF DEAD SKIN (surgical debridement)
• Application of HEAT THERAPY during second or subsequent visit to medical personnel
• Use of WHIRLPOOL BATH THERAPY during second or subsequent visit to medical personnel
• POSITIVE X-RAY DIAGNOSIS (fractures, broken bones, etc.)
• ADMISSION TO A HOSPITAL or equivalent medical facility FOR TREATMENT

The following are generally considered first-aid treatment (that is, a one-time treatment of minor injuries and subsequent observation) and should not be recorded if the work-related injury does not involve loss of consciousness, restriction of work or motion, or transfer to another job:

• Application of ANTISEPTICS during first visit to medical personnel
• Treatment of FIRST DEGREE BURN(S)
• Application of BANDAGE(S) during any visit to medical personnel
• Use of ELASTIC BANDAGE(S) during first visit to medical personnel
• Removal of FOREIGN BODIES NOT EMBEDDED IN EYE if only irrigation is required
• Removal of FOREIGN BODIES FROM WOUND -- if procedure is UNCOMPLICATED, and performed by tweezers or other simple technique
• Use of NON-PRESCRIPTION MEDICATIONS AND administration of a single dose of PRESCRIPTION MEDICATION on first visit for minor injury or discomfort
• SOAKING THERAPY on initial visit to medical personnel or removal of bandages by SOAKING
• Application of hot or cold COMPRESS(ES) during first visit to medical personnel
• Application of OINTMENTS to abrasions to prevent drying or cracking
• Application of HEAT THERAPY during first visit to medical personnel
• Use of WHIRLPOOL BATH THERAPY during first visit to medical personnel
• Negative X-Ray Diagnosis
• OBSERVATION of injury during visit to medical personnel

The portion of the OSHA No. 200 form to the right of the dotted vertical line is used to summarize injuries and illnesses in an establishment for the previous calendar year. Every nonexempt employer who is required to keep OSHA records must prepare an annual summary for each establishment, based on the information contained in the log for each establishment.

The summary is prepared by totaling the column entries on the log (or its equivalent) and signing and dating the form's certification portion at the bottom of the page.

Each employer should post a copy of the establishment's summary in each establishment. The summary covering the previous calendar year should be posted no later than February 1 and remain in place until March 1.

A failure to post a copy of the establishment's annual summary may result in citations and an assessment of penalties pursuant to Sections 9 and 17 of the Act. Such a notice (or notices) should be posted by the employer in a conspicuous place or places where notices to employees are customarily posted. Each employer should take steps to ensure that such notices are not altered, defaced, or covered up by other material.

For every injury or illness entered on the log, it's necessary to record additional information on the supplementary record, OSHA No. 101.

The supplementary record describes how the injury or illness exposure occurred, lists the objects or substances involved, and indicates the nature of the injury or illness and the body part(s) affected.

Ordinarily, injury and illness records must be kept for each establishment covered by the Occupational Safety and Health Act. The regulations require that records be located and maintained to help government agencies administer and enforce the act, to increase employer-employee awareness, and to promote injury and illness prevention.

Injury and illness records (the log and summary) must be kept for every physical location where operations are performed. Under the regulations, the location of the records depends upon whether the employees are associated with fixed establishments. The log and summary must be retained in each establishment for five calendar years following the end of the year to which they relate.

This article was published with permission from Safety Information Currents. Its editor, Bill Grieb, may be contacted at (310) 454-2100.