HR Management & Compliance

Health And Safety: OSHA Recordkeeping Rules Are Changing

Federal OSHA’s revised rules for recording workplace injuries and illnesses took effect January 1. Although they’re not yet formally implemented in California, a Cal/ OSHA spokesman told CEA the agency expects the rules to be officially adopted by mid-February and is advising California employers to start following the new federal guidelines now for all 2002 injury and illness recordkeeping.

The rules apply to most employers, but there are partial exemptions for employers in certain industries and those with 10 or fewer workers at all times in the previous calendar year. Employers in low-hazard industries such as retail, service, finance, insurance or real estate generally don’t have to keep OSHA injury and illness records. And starting in January, businesses such as personnel services, dry cleaners, janitorial services and auto supply services will be subject to the recordkeeping requirements. We’ll review the most important changes.

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Recording Criteria

The former rules had separate guidelines for recording work-related injuries and work-related illnesses. Now one set of criteria is used for both. You must record all work-related injuries or illnesses, including musculoskeletal disorders (MSDs), that result in one of the following: death; days away from work; restricted work or transfer to another job; loss of consciousness; diagnosis of a significant injury or illness by a health care professional; or medical treatment beyond first aid. There is now a specific list of first aid procedures, and all other treatment not on this list is medical treatment.

All needlestick and sharp instrument injuries involving contamination by another person’s blood or other potentially infectious material must be recorded, regardless of days away or restricted work. Special rules also apply to cases involving work-related transmission of tuberculosis, and removal from the workplace for exposure to hazardous substances under OSHA standards. Additional rules for recording MSDs will take effect Jan. 1, 2003.

Identifying Work-Related Conditions

The rules also contain guidelines to determine whether certain conditions are work-related and therefore must be recorded. Here are some key examples:


  1. Common conditions. Cases arising from common colds and flu, eating and drinking food and beverages, blood donations and exercise programs don’t need to be recorded.


  2. Pre-existing conditions. A sig-nificant degree of aggravation is required before a pre-existing injury or illness is considered work-related.


  3. Mental illnesses. Mental illness is work-related only if the employee voluntarily provides the employer with a health care professional’s opinion that the employee has a work-related mental illness.


  4. At-home injuries and illnesses. These are work-related if they occur while the employee performs paid work at home and the condition was caused by working and not the general home environment.

New Reporting Forms

The recordkeeping forms have also been revised.


  1. OSHA Form 300, Log of Work-Related Injuries and Illnesses. This form has been simplified and can now be printed on smaller, legal-sized paper. Note that you must protect employees’ privacy by withholding an individual’s name on Form 300 for certain types of sensitive injuries and illnesses, such as sexual assaults, HIV infections and mental illnesses. You also have to omit descriptive information about sensitive injuries that would reveal the employee’s identity. Employees are entitled to see their own injury and illness records.


  2. OSHA Form 301, Injury and Illness Incident Report. The new version requires additional data about how the injury or illness occurred.


  3. OSHA Form 300A, Summary of Work-Related Injuries and Illnesses. The revised summary form includes additional data to help calculate incidence rates. A company executive has to certify the summary’s accuracy. For 2000 data, you’re still required to post the summary during the month of February 2002. But starting in 2003, you’ll have to post the annual summary from February 1 through April 30.

Note that you don’t have to record all required information on official OSHA forms but rather can keep it on computers, at a central location or on alternative forms if the data is compatible and can be produced when needed.