As most of you know, OSHA has implemented new requirements for reporting injuries and illnesses and also has revised the list of industries which are exempt from maintaining injury and illness records. How will this affect you?
Let’s keep it simple: under OSHA’s new rules for reporting and recording, most employers are required to report to OSHA within 8 hours, any work-related fatalities. This requirement has not changed. However, if an employee has a work-related incident which results in in-patient hospitalization of one or more workers, amputation or loss of an eye, the incident must be reported to OSHA within 24 hours. If the in-patient hospitalization, amputation, or loss of an eye occurs beyond 24 hours of the work-related incident, while likely recordable on the OSHA 300, it need not be reported to OSHA unless the injury is a mechanical power press point of operation injury. For example, if an employee has a work-related injury to his/her arm and it is decided two days later that the arm must be removed, the amputation need not be reported to OSHA. See the related EI white paper for more details regarding mechanical power press injuries.
Reporting Reportable Incidents
Employers may report incidents by:
- Calling OSHA’s free and confidential number at 1-800-321-OSHA (6742), or
- Calling your closest Area Office during normal business hours, or
- Using the new online form that will soon be available.
The related EI white paper contains a table which provides a side-by-side comparison of the new and old reporting requirements.
Most employers will not be affected by the new recording requirements. However, some employers who were previously not required to maintain injury/illness records are no longer exempt. The size exemption has not changed. Any employer who has had no more than 10 employees throughout the calendar year is exempt from maintaining injury and illness records. If, however, an employer has had 11 or more workers, including temps, on even a single day during the year, that employer must complete required forms including OSHA forms 300, 301 and 300A for that calendar year.
Under previous rules, some employers were not required to maintain these records simply because they were in what has been deemed a low hazard industry and therefore, were given a low hazard exemption. OSHA has revised the list of exempt industries to reflect more recent injury and illness data and to incorporate the North American Industry Classification System (NAICS) in lieu of the earlier Standard Industrial Classification (SIC) system. To see the revised list as well as the new list of industries now required to maintain OSHA injury and illness records, go to OSHA.gov and click “Reporting Fatalities and Severe Injuries.”
The implementation date for these changes was 1/1/2015 for employers in states under federal jurisdiction. For those employers located in State Plan states, the implementation date may vary. To find out the implementation date for states operating under State Plans, you can read EI’s extended white paper on the subject or visit www.OSHA.gov.
To see the list of those employers exempt from OSHA injury/illness recordkeeping, go to the following links:
Feel free to contact Bill Taylor, CSP at firstname.lastname@example.org or (919) 459-5249 if you have questions.