SECTION
15.10 OSHA RECORDKEEPING
Note: Revised OSHA Recordkeeping requirements
effective January 1, 2002
OSHA records are required to be
kept by all departments in state government.
The main components are the Worker’s Compensation First Report of
Injury, the OSHA Form 300 (Log of Work-Related Injuries and Illnesses), and the
OSHA Form 300A (Summary of Work-Related Injuries and Illnesses).
The First Report of Injury
(labeled Employers Work Injury Report, Employers First Report of Injury) is
used by the Industrial Commissioner’s office as the standard form for workers’
compensation services in Iowa. The
First Report of Injury or a copy of the original must be kept on-site for five
years.
The revised rule is designated to
produce better information about occupational injuries and illnesses while
simplifying the overall recordkeeping system for employers. The rule will better protect employees’
privacy and allow employers’ greater flexibility to use computers for
recordkeeping.
Key provisions of the
recordkeeping rule are:
· Updates
OSHA Form 300
· Updates
OSHA Form 300A
· All State
departments will continue to use the First Report of Injury
· Eliminates
different criteria for recording work-related injuries and illnesses; one set
of criteria will be used for both.
· Requires
records to include any work-related injury or illness resulting in one of the
following: death; days away from work; restricted work or transfer to another
job; medical treatment beyond first aid; loss of consciousness; or diagnosis of
a significant injury/illness by a physician or other licensed health care
professional.
· Includes
new definitions of medical treatment, first aid, and restricted work to
simplify recording decisions.
· Requires a
significant degree of aggravation before a preexisting injury or illness
becomes recordable.
· Adds
additional exemptions to the definition of work-relationship to limit recording
of cases involving the eating and drinking of food and beverages, common colds
and flu, blood donations, exercise programs, mental illness, etc.
· Clarifies
the recording of “light duty” or restricted work cases. Requires employers to
record cases when the injured or ill employee is restricted from their “normal
duties” which are defined as work activities the employee regularly performs at
least once weekly.
· Requires
the employers to record all needlestick and sharps injuries involving
contamination by another person’s blood or bodily fluids.
· Includes
separate provisions describing the recording criteria for cases involving the
work-related transmission of tuberculosis or medical removal under OSHA
standards.
· Eliminates
the term “lost workdays” and focuses on days away or days restricted or
transferred. Also includes new rules
for counting that rely on calendar days instead of workdays. Limits calendar days to a maximum of 180
days per event.
· Requires
employers to establish a procedure for employees to report injuries and
illnesses and to train their employees how to report. Employers are prohibited from discriminating against employees
who do report. For the first time,
employee representatives will have access to those parts of the First Report of
Injury relevant to the employees they represent.
· Protects
employee privacy by (1) prohibiting employers from entering an individuals name
on OSHA Form 300 for certain types of injuries/illnesses; (2) providing
employers the right not to describe the nature of sensitive injuries where the
employee’s identity would be known; (3) giving employee representatives access
only to the portion of the First Report of Injury which contains no personal
identifiers; and (4) requiring employers to remove employees’ names before
providing data to persons not provided access rights under the rule.
· Requires
the annual summary to be posted for three months instead of one. Requires certification by a company
executive.
· Changes
the reporting of fatalities and catastrophes to exclude some motor carrier and
motor vehicle accidents.
· For
detailed information on recordkeeping rules, view OSHA’s website at: www.osha.gov/recordkeeping/index.html