Division of Labor Services

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Iowa Division of Labor 
OSHA Recordkeeping Requirements

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OSHA Recordkeeping Regulations Revised
The Occupational Safety and Health Administration announced revisions to the system employers use to track and record workplace injuries and illnesses. The final rule became effective on January 1, 2002 and affects approximately 1.3 million establishments.

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 also better protect employees' privacy.

Some of the key provisions of the recordkeeping rule are:

  • Updates OSHA Form 300
  • Updates OSHA Form 301
  • Updates OSHA Form 300A
  • 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 other 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.
  • Requires employers to establish a procedure for employees to report injuries and illnesses and tell 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 OSHA 301 form relevant to the employees they represent.
  • Protects employee privacy by (1) prohibiting employers from entering an individual's name on Form 300 for certain types of injuries/illnesses (e.g., sexual assaults, HIV infections, mental illnesses, etc.); (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 Form 301 which contains no personal identifiers; and (4) requiring employers to remove employees' names before providing the data to persons not provided access rights under the rule.
  • Requires the annual summary to be posted for 3 months instead of 1. Requires certification of the summary by a company executive.
  • Changes the reporting of fatalities and catastrophes to exclude some motor carrier and motor vehicle accidents.
  • For detailed information on the final recordkeeping rules, view OSHA's web site at:  http://www.osha.gov/recordkeeping/index.html.



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