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OSHA 300 Recordkeeping

 Changes effective:

January 1,2004

January 1, 2002

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Some of the revisions to the recordkeeping requirements were:

• In the December 17, 2002 Federal register (67 FR 77165-77170) OSHA announced its decision to modify the OSHA Form 300 to include an occupational hearing loss column. Employers required to complete the injury and illness forms must begin to use the modified forms on January 1, 2004.  (see OSHA 300 Form)

• Starting January 1, 2002, organizations must use OSHA 300, 300-A, and 301 forms, or equivalent forms, for recordable injuries and illnesses unless they are considered "Partially Exempt" from the Reporting Requirements based upon. The OSHA 300 form is called the Log of Work-Related Injuries and Illnesses, the 300-A is the Summary of Work-Related Injuries and Illnesses, and the OSHA 301 form is called the Injury and Illness Incident Report.

Note: Some employers are considered "Partially Exempt" from the reporting requirements, based upon being considered a "non-hazardous" industry, unless they are asked in writing to do so by OSHA, the Bureau of Labor Statistics (BLS), or a state agency operating under the authority of OSHA or the BLS.  However, all employers, including those partially exempted by reason of company size or industry classification, must report to OSHA any workplace incident that results in a fatality or the hospitalization of three or more employees.

• OSHA intended for employers to make a clean break with the former OSHA 200 system. The new rule replaced the old rule on the effective date of the new rule, and OSHA will discontinued the use of all previous forms, interpretations and guidance on that date.

• If a physician or other licensed health care professional recommends days away from work, organizations should encourage their employee to follow that recommendation. However, the days away must be recorded whether the injured or ill employee follows the physician or licensed health care professional's recommendation or not.

• Organizations must record all work-related needlestick injuries and cuts from sharp objects that are contaminated with another person's blood or other potentially infectious material (as defined by 29 CFR 1910.1030).  Organizations must enter the case on the OSHA 300 Log as an injury. To protect the employee's privacy, organizations may not enter the employee's name on the OSHA 300 Log.

• Privacy Concern Cases:  Organizations are required to withhold the injured or ill employee’s name from the OSHA 300 log for injuries and illnesses defined by the rule as “privacy concern cases” and instead to enter “privacy concern case” in the space where the employee’s name would normally be entered in an injury or illness meeting the definition of a privacy concern case occurs.  Organizations must also keep a separate, confidential list of these privacy concern cases, and the list must include the employee’s name and the case number from the OSHA 300 log.

Organizations must consider the following injuries or illnesses to be privacy concern cases:

(i) An injury or illness to an intimate body part or the reproductive system;

(ii) An injury or illness resulting from a sexual assault;

(iii) Mental illnesses;

(iv) HIV infection, hepatitis, or tuberculosis;

(v) Needlestick injuries and cuts from sharp objects that are contaminated with another person's blood or other potentially infectious material; and

(vi) Other illnesses, if the employee independently and voluntarily requests that his or her name not be entered on the log.

• Covered employees.  Organizations must record on the OSHA 300 Log the recordable injuries and illnesses of all employees on the Organizations payroll, whether they are labor, executive, hourly, salary, part-time, seasonal, or migrant workers.  Organizations also must record the recordable injuries and illnesses that occur to employees who are not on the Organizations payroll if they supervise these employees on a day-to-day basis.

For assistance with Safety Management Programs and "OSHA Record-Keeping and Compliance" contact:

HRConsulting@hralt.com

Link to OSHA-300 form; new as of 1/1/2004 (pdf)

	Web www.hralt.com

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