OSHA Recordkeeping: Do You Really Need To Do It?

In the immediate aftermath of a fatal or severe workplace injury that requires hospitalization of the employee, it is rarely the first thought of the organization, “We need to report this to the Occupational Health and Safety Administration.” Rather, initial considerations have to do with seeking medical attention, followed by rectifying the source of the incident. However, there are some time sensitive elements while notifying OSHA. All fatalities that occur in the workplace need to be reported to OSHA within 8 hours.  All hospitalization of an injured worker must be reported to OSHA within 24 hours.  

While OSHA reporting and recordkeeping may not seem as urgent as providing care to an unconscious employee or a toppled forklift, the process is a vital part of your requirements under the OSHA standards, and for many organizations, an incident that isn’t recorded and reported in a timely manner can bring significant expenses, as the minimum fine for a single late or missing report is $5,000.

The Importance of Recordkeeping

While regulatory penalties are certainly worth avoiding, there are plenty of other reasons to prioritize recordkeeping and reporting. Consider the following benefits identified by OSHA:

1. Tracking injuries and accidents can improve prevention.  Records may expose trends and themes among issues plaguing a facility. If you can anticipate what’s likely to happen, you can proactively protect your workforce (rather than merely responding to incidents), which is the ultimate goal of any EHS program.
2. Using data helps identify problem areas and processes to correct hazardous workplace conditions.  The more you know, the better you can identify and minimize existing risks. Go a step further and analyze the data, and you’ll be able to determine gaps and insufficiencies in your safety program. You may learn that employees need more training, or that a certain procedure is prone to error.
3. Better administer company safety and health programs.  Again, the best way to determine the effectiveness of your program is through documented data. By analyzing your records, you can find out if you’re truly, tangibly improving your safety results.
4. As employee safety awareness improves, workers are more likely to follow safe practices and report hazards.  Recordkeeping and workplace safety are a virtuous cycle. The more you know, the more awareness you’ll have around the facility in key areas such as training or personal protective equipment. When employees understand that proper use of PPE demonstrably correlates to improved safety, for example, they have no reason not to protect themselves and keep an eye on their co-workers’ behavior.

Exemptions from OSHA Recordkeeping Requirements

While keeping records is almost always a good idea, it’s not actually required for every organization.

Small organizations are exempt from most OSHA recordkeeping requirements. If you have 10 or fewer employees at all times throughout the year, you don’t have to keep safety records. You don’t need to fill out OSHA 300, 301, and 300A forms if you choose not to.

Companies in low-hazard industries are partially exempt. If you operate in what OSHA deems a “low-hazard industry,” your organization must still comply with reporting claims, but you are not required to maintain OSHA 300 logs (although doing so remains a best practice). To determine whether your work environment is considered low-hazard, you’ll need to find out your North American Industry Classification System (NAICS) code, then check to see if your code shows up on OSHA’s listing of partially exempt industries.  

https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html

Keep in mind that we’re talking about partial exemptions. If OSHA or any other agency requests that you keep these forms—if the Bureau of Labor Statistics performs a random sampling, for example, and requires you to maintain forms throughout the year—then you’re still on the hook.

Exempted or not, ALL EMPLOYERS MUST REPORT WORKPLACE-RELATED FATALITIES AND SERIOUS INJURIES. And if you do keep OSHA logs, be sure to maintain your records for at least 5 years.

Back to the question posed in the title of this article: Do you really need to comply with OSHA recordkeeping requirements? For many companies, the answer is an unequivocal “yes.” For the rest, it’s a “yes, you probably should.” Regardless of whether your organization is exempt or not, recordkeeping is a best management practice. And on the plus side, records help you prevent your workers’ compensation costs from spiking.