Safety Tidbit # 41 – OSHA Recordkeeping Changes

Safety Tidbit # 41 – OSHA Recordkeeping Changes

I was conducting a visit at a client this week, and I asked for a copy of his OSHA 300A form for 2015, which I do at each visit.  The representative said we didn’t have any recordable injuries last year, so we didn’t think we had to fill out the form.  So I verified their NAICS code with him to ensure they were not listed on OSHA’s list of Partially Exempt Industries (they were not) and I asked how many employees they had in 2015. The representative answered 16, but a few had to be laid off recently so now they were down to 12 or 13.  I explained that all employers not specifically exempted by OSHA must complete the OSHA 300A Summary of Injuries and Illnesses and post it from February 1 thru April 30 for employees to review and comment on.

I followed up the conversation on the 300A form and asked did you have any incidents that although they did not end in “recordable” injuries required first aid or maybe made the employee or others around them take pause?  The representative said they had one laceration, but he didn’t lose any time from work.  So we had another training opportunity, I asked if he sought medical attention outside the facility and if so, what care was rendered.  The employer said yes the worker went to the emergency room and received stitches.  I said well that sounds like care beyond first aid as not many can put in stitches. Now, had the emergency room put on a “butterfly” closure for the laceration the care still may have been considered first aid.

While on the topic of injury reporting, I asked if he was aware of the 2015 changes to the reporting requirements.  He just stared at me and said he was glad he asked consultation in to help get them on track.  I let him know that for amputations, loss of an eye or inpatient hospitalizations of one or more employees that OSHA must be called within 24 hours (see OSHA’s Web page). I also reminded him that fatalities must still be reported within 8 hours. 

To further complicate matters, I told him that very soon some employers will need input their OSHA 300 information online annually (see OSHA’s Web page).  All establishments with at least 250 employees must log into the web page and enter their data. Also, for employers with specific NAICS, as defined by OSHA list in the standard, and 20 or more employees must also report their injury information to OSHA via the webpage.  Which, his company happened to fall into, but he is currently under the 20 employee requirement.  However, I reminded him this employee count takes in all part-time and temporary and seasonal employees.  We discussed how this will impact construction as they may only have a few permanent employees but hire many part-time, temporary or seasonal employees as the job requires and will easily go above the 20 employee threshold set by OSHA. 

The last topic in recordkeeping that we discussed was the need to involve employees in the recordkeeping system. Specifically, they must be informed as to how they are to report work-related injuries or illnesses.  You must tell each employee that:

(A) Employees have the right to report work-related injuries and illnesses; and
(B) Employers are prohibited from discharging or in any manner discriminating against employees for reporting work-related injuries or illnesses.

Thus started my visit and why so many small employers are grateful for the assistance PA OSHA Consultation provides to them.  When they ask for it.  Thanks for reading!  ~Bryan