OSHA-record-keeping

With so much emphasis being placed on CSA scores, FMCSA and DOT compliance within the transportation industry, OSHA compliance is often the furthest thought from most safety directors’ minds. For example, if a tractor returns to the shop after a failed roadside inspection due to a brake issue, the primary concern is typically getting the issue corrected and the tractor back out on the road. But does anyone think about whether proper personal protection equipment (PPE) was used to protect the mechanic from possible chemical exposure if brake cleaner was utilized? Is there a safety data sheet (SDS) on file for the brake cleaner? Or for what action needs to be taken if the mechanic was injured while making a repair?

OSHA compliance should be a primary objective for every fleet. Fines quickly add up and, depending on the severity of the violation, OSHA has the authority to shut down an operation. In fact, one fleet was fined $8,000 for inadequate and incomplete recordkeeping, which happens to be one of the most common OSHA violations. Under the OSHA recordkeeping regulation (29 CFR 1904), employers are required to prepare and maintain records of serious occupational injuries and illnesses using the OSHA 300 Log.

What needs to be recorded?

Injuries are recordable if they result in the following:

  • Death
  • Days away from work
  • Restricted work
  • Transfer to another job
  • Medical treatment beyond first aid
  • Loss of consciousness
  • Work-related diagnosed case of cancer
  • Chronic irreversible diseases
  • Fractured or cracked bones/teeth punctured eardrums.
As a friendly reminder, Protective Insurance would like to point you towards OSHA’s recordkeeping requirements found in 29 CFR 1904, specifically the requirement to post an annual summary. This summary, known as the OSHA Form 300A, should be completed and posted no later than Feb. 1 of the year following the summarized year. OSHA requires this posting to be placed in a conspicuous location and to remain in place until April 30.

How do I track days away from work or restricted work activity?

Count the number of calendar days the employee was on restricted work activity or was away from work as a result of the recordable injury or illness. Do not count the day on which the injury or illness occurred in this number. Begin counting days from the day the incident occurs. If a single injury or illness involved both days away from work and days of restricted work activity, enter the total number of days for each. You may stop counting days of restricted work activity or days away from work once the total of either or the combination of both reaches 180 days.

If a physician or licensed health care professional recommends that the employee return to work but he or she stays home, you must end the count of days away from work on the date the worker was recommended to return. If the employee leaves your company for a reason unrelated to the injury or illness, such as retirement or to take another job, you may stop counting days away from work.

What is considered a work-related accident?

If an event or exposure in the work environment caused or contributed to the resulting condition or significantly aggravated a pre-existing condition, it is work-related. The work environment includes the physical location but also the equipment or materials used.

For more information, visit www.osha.gov/recordkeeping/index.html or contact Owen McLean in Loss Prevention & Safety Services at omclean@protectiveinsurance.com or (317) 636-9800 x2695.

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