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OSHA Recording vs. Reporting

recording pic This article addresses the difference between OSHA recording and reporting and what your obligations are. As the employer, you are required by OSHA to record and report certain workplace incidents. 

Recording is the act of documenting work-related incidents as specified by OSHA. To remind you, the three OSHA recordkeeping forms are the OSHA Form 300, OSHA Form 301, and OSHA Form 300A. The OSHA Form 300A must be posted for all employees to view from February 1 to April 30.  These forms are to be maintained on-site and must be made available upon request from OSHA. Please know that OSHA will request these forms from the last three years.  Unless previously requested by OSHA, you may have only been required to maintain these forms since January 1, 2015. Therefore, you will need to notify OSHA, only after an OSHA request, that you were exempt until the January 1, 2015 standard update.

Reporting is the act of notifying OSHA, within a certain timeframe, after a workplace fatality or specified incident.

You have the duty to directly report to OSHA if any of the following occurs:

  • Workplace fatality – You have the duty to report to OSHA within 8 hours after the death of any employee as a result of a work-related incident.
  • In-Patient hospitalization – You have the duty to report to OSHA within 24 hours after an in-patient hospitalization of one or more employees resulting from a work-related incident.
  • Employee amputation – You have the duty to report to OSHA within 24 hours after an employee limb amputation as a result of a work-related incident.
  • Employee loss of an eye – You have the duty to report to OSHA within 24 hours after an employee loses an eye as a result of a work-related incident.

You must report via:

  • Telephone or in person to the OSHA Area Office that is nearest to the site of the incident;
  • Telephone to the OSHA toll-free central telephone number, 1-800-321-OSHA; or by
  • Electronic submission using the reporting application located on OSHA’s public web site at www.osha.gov.

Since in-patient hospitalization would be the most common, allow me to further specify this requirement. Prior to January 1, 2015, the OSHA Standard required you to report a workplace occurrence that resulted in the in-patient hospitalization of 3 or more employees. You are now required to report to OSHA a workplace occurrence that resulted in the in-patient hospitalization of 1 or more employees. In-patient hospitalization is defined as the formal admission to the in-patient service of a hospital or clinic for care or treatment. You’re an in-patient when you’re formally admitted to the hospital with a doctor’s order. Additionally, any patient who stays in the hospital for one or more nights for treatment is considered in-patient. Furthermore, employers must report an in-patient hospitalization due to a heart attack, if the heart attack resulted from a work-related incident.

Employers do not have to report an event if it:

  • Only involved a hospital stay for observation or diagnostic tests.
  • Resulted from a motor vehicle accident on a public street or highway. Employers must report the event if it happened in a construction work zone.
  • Occurred on a commercial or public transportation system (airplane, subway, bus, train, etc.).
  • Occurred more than 30 days after the work-related incident in the case of a fatality or more than 24 hours after the work-related incident in the case of an in-patient hospitalization, amputation, or loss of an eye.

REMEMBER: PROACTIVE SAFETY BEATS REACTIVE SAFETY!

 

About the Author:  Christopher J. Zanetti is the President of EDMC Safety & Health, a consulting firm assisting employers with OSHA compliance. Our firm specializes in serving the safety and health needs of General Industry with a client emphasis in the automotive, hospitality and dental industries throughout Western Pennsylvania, Eastern Ohio and Northern West Virginia regions.  The overall mission of EDMC Safety & Health is to assist clients in establishing and maintaining a workplace free from recognized hazards. Our on-site safety training and programs meet OSHA regulations and encourage best practices for safety and health in the workplace. 

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