By Bethany Cantrell and Kyle Zanon
The challenges for OSHA recordkeepers are numerous. They must understand what construes a recordable incident, know what forms to file and rigorously keep records. The job hasn’t gotten any easier with COVID-19.
That’s because COVID-19 is a recordable illness if an employee is infected due to performing work-related duties, and it meets three criteria set forth by the Centers of Disease Control and OSHA. Employers are responsible for recording confirmed COVID-19 cases if it can be determined the virus was contracted at work and it required days away from the workplace.
COVID-19 or not, the consequences for failing to properly keep OSHA records can be severe: A citation for improper record keeping could bring a fine of up to $13,653 for a first offense, while the penalty classification remains on the company record for five years.
With exceptions for organizations with fewer than 10 employees and companies in exempt industries,1 failure to maintain and post OSHA 300A logs (the logs on which employers record certain work-related injuries and illnesses) in a “conspicuous place” between February 1 until April 30 results in a penalty and could lead to the loss of opportunities on certain job sites with other companies.
What to report and when
All employers must report all work-related fatalities, amputations or loss of an eye at work and inpatient hospitalizations. Any inpatient service of a hospital or clinic for care or treatment (not diagnostic testing or observation), any amputation, or loss of an eye resulting from a work-related incident must be reported within 24 hours. A fatality that occurs within 30 days of a work-related incident must be reported within eight hours of the employer finding out about the fatality.
Work-related COVID-19 cases (when the illness resulted in hospitalization or death) and work-related incidents like accidents must be reported to OSHA within eight hours. Most of these cases have been reported as respiratory illness and the citations issued to businesses related to COVID-19 have been for respiratory requirements. (You can review OSHA guidelines on COVID-19 here.)
All reportable incidents must be logged on OSHA’s recordkeeping forms.
It’s important to note that just because something is an insurance claim doesn’t necessarily mean it’s an OSHA recordable event. You can find a brief explanation of OSHA recordkeeping requirements at their site.
The information and the forms you need
The basic elements of a news story — the who, what, where, when, why and how of an event — can serve as a model for filling out OSHA incident reports. The report should include the names and titles of the employees involved, a brief description of the work-related incident, where it happened, the time it occurred and the circumstances leading to the incident. You’ll need to file OSHA’s record-keeping forms. (Visit OSHA's Injury and Illness Recordkeeping and Reporting Requirements page for more information.)
Follow these tips to maintain compliance with OSHA record keeping:
- Have policies and procedures in place. Employees need to know how to stay safe and the protocols to follow. An employee needs to be in charge when action is required, and that employee must understand how to tackle an issue promptly and correctly document it.
- Take the time to train. Provide your recordkeepers with the necessary tools to do their job. As those tasked need to fundamentally understand recordkeeping and reporting requirements, annual training can help recordkeepers stay current. State OSHA programs often offer training classes.
- Enforce the rules. Following procedure and properly documenting work-related injuries and illnesses is not optional and establish a process to audit your recordkeeping documents regularly, as well as monitor the work of those maintaining the forms to ensure compliance.
Contact a HUB Risk Services expert for more information on instituting the right policies and procedures for proper OSHA recordkeeping and reporting.
1U.S. Department of Labor, “Non-Mandatory Appendix A to Subpart B -- Partially Exempt Industries,” accessed March 2, 2021.
