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OSHA Electronic Recordkeeping Update

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OSHA issued a proposed rule on July 27th that would roll back certain aspects of the Recordkeeping Standard.

Affected employers with more than 250 employees were required to submit detailed injury and illness information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses), minus the injured employee’s name. OSHA’s electronic recordkeeping system is currently not accepting this detailed information and will not until the status of this proposed rule is settled.

The recordkeeping website is still accepting information from the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses) which is a rollup of individual injuries and detail from the 300 form. Worker advocacy groups and trade unions argue the lack of detail from the 300 logs will hide the dangers present in workplaces, but information from the 300A log provides all the information necessary to calculate the various incident rates used to benchmark safety performance.

Because the fields on the 300 form reflect the most basic information gathered after an injury or illness, the form lacks the context and detail necessary to determine the root cause of the injury. While employers are always held responsible for the health and safety of employees, many accidents are the result of the unpreventable employee misconduct. The lack of detailed information could be used, unfairly, against employers.

It’s important to remember that incident rates are lagging indicators. Knowing where you’ve been is important, but focus more attention on leading indicators that can be identified and corrected before an injury occurs. Leading indicators include safety observations to identify unsafe conditions and behaviors, tracking regularly scheduled safety training, and measuring the culture of safety.

Even though OSHA is proposing to eliminate the detail that causes heartburn for employers, it is still important to complete your OSHA 300 and 300A logs correctly. Know the rules and only record injuries and illnesses required to be reported on the log. Over-reporting can cause the incident rates publicly displayed on the internet to appear to be higher than what they really are.

Please join us and learn more at the January OSHA Recordkeeping workshops sponsored by Horton Safety Consultants.

Compliance related topics:

  • OSHA requirements for recordkeeping and reporting
  • OSHA Form 300 – Log of Work-Related Injuries and Illnesses
  • OSHA Form 301 – Injury and Illness Incident Report
  • OSHA Form 300A – Summary of Work-Related Injuries and Illnesses

 

 

Material posted on this website is for informational purposes only and does not constitute a legal opinion or medical advice. Contact your legal representative or medical professional for information specific to your legal or medical needs.

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