Each year 180,000 organizations send data to the BLS on injuries and illnesses that occurred at their workplace. If an organization's rate of incidence is higher than the national average, they can be targeted* for an inspection. OSHA's latest proposed rule intends to change how records are provided to OSHA while simultaneously adding an additional 260,000 organizations as required to report their incident performance. Therefore, it is vital that organizations ensure the records they maintain now and in the future are accurate, and that they learn about how OSHA's proposed rule may impact their organization.

1. OSHA Recordkeeping:
An Annual Opportunity
Presented by:
Aaron Lilach, CSM
Founder & CEO
Assured Services, LLC
Simplifying a Complex World
A few words from our attorneys: all recommendations from Assured Services, LLC are purely advisory to help organizations
identify and effectively control exposures to loss. We do not infer or imply in the making of recommendations and comments
that all possible hazards are noted or to indicate that other hazards do not exist. The maintenance of safe
premises, operations, vehicles and equipment, the avoidance of unsafe conditions and practices, and compliance with
Federal, State and local statutes and laws are the sole responsibility of the session attendee, client or prospective client.

2. Webinar Objectives
• Provide you with a simplified explanation of
29 CFR 1904, OSHA’s recordkeeping rule.
• Allow you to learn the basics of recordkeeping
requirements, including timelines and what
forms are required.
• Discuss the importance of OSHA incident rates
to your organization.
• Review the new reporting requirements being
proposed by OSHA.

3. The Formula
Work
Related
Incident
Meets
Criteria
OSHA Recordable

4. Work Comp Vs. Recordable
• Workers’ Compensation determinations do NOT
impact OSHA recordability.
– Some cases may be OSHA recordable and
compensable.
– Some cases may be compensable, but not OSHA
recordable.
– Some cases may be OSHA recordable, but not
compensable.

5. Incident
• New or aggravated injury or illness
• Not an exposure
– Unless exposure results in injury or illness
Incident

6. Work Related
Work
Related
• Work environment:
– Caused incident
– Contributed to incident
– Significantly aggravated previous injury or illness

7. Typically Not Work Related
•
•
•
•
•
No discernable cause
Member of general public
Results at work but caused elsewhere
Voluntary wellness participation
Food or drink consumption
– Unless contaminated by work atmosphere
•
•
•
•
Personal tasks off duty
Self-inflicted
Crashes while commuting (including lots)
Colds, flu, mental illnesses - unless caused by work

8. Recording Criteria
• Incident resulting in:
– Death
– Loss of consciousness
– Days away from work
– Restricted work activity or job transfer
– Medical treatment beyond first aid
Meets
Criteria

9. The Formula
Work
Related
Incident
Meets
Criteria
OSHA Recordable
Remove one, and the
incident is not
recordable.

10. Records Required
• Utilize the following forms:
– OSHA Form 301 – Injury and Illness Incident
Report
– OSHA Form 300 – Log of Work-Related Injuries
and Illnesses
– OSHA Form 300A – Summary of Work-Related
Injuries and Illnesses
• File and update as necessary for 5 years
Forms available for free here: https://www.osha.gov/recordkeeping/RKforms.html

11. Important Timelines
• After the report of an injury:
– 7 days to record on 301 and 300
– Pro Tip: make this a part of your incident
investigation process!
• After a fatality or 3 or more hospitalized:
– Notify OSHA within 8 hours (800.321.OSHA)

12. Important Timelines
• At the end of the calendar year (NOW!)
– Review 300 log
– Create 300A (annual summary)
– Certify the summary
– Post from 2/1 thru 4/30

13. Counting Days
•
•
•
•
•
Skip day of incident
Count calendar days, not work days
Use doctor releases, not employee “preference”
Cap days at 180
Stop counting if they leave
– Unless leaving due to injury, then estimate
• Estimate days if DART extends from year to year

14. Medical Treatment or First Aid
•
•
•
•
•
ER may not equal recordable!
Doctor visit may not equal recordable!
First aid treatment is not recordable!
Diagnostics are not recordable!
Any prescribed med is recordable!

15. The Complications
• Multiple locations
– Central location recordkeeping OK if can be
reported and produced within 7 days
– Same Employer? Injuries are location specific
– Separate Employer? Injuries are home based

16. Temp Workers
• General rule: if you supervise them, they are
your incidents!

17. The Meat & Potatoes
(# of recordables X 200,000)
# of hours worked
= OSHA Recordable Rate
• If this is above nat’l avg… your workplace will
be targeted for inspection!
Calculate your rate here: http://data.bls.gov/iirc/

18. Action Plan
• Ensure all incidents are reported
• Audit all records of incidents for recordability
• Monitor your performance more than OSHA
requires
• Take action BEFORE your numbers surpass the
nat’l avg

19. OSHA’s Future Plans
• Now: 180,000 businesses submit records
• Future: 440,000 anticipated to submit records
• How?
– Online submission of records, based on employee
count
– 21-250 employees, annually submit:
• 300A annual summary
– 250+ employees, quarterly submit:
• 300 log
• 301 individual incident reports

20. OSHA’s Future Plans
• Oh, and BTW…
ALL DATA WILL BE PUBLIC INFO!

21. OSHA’s Future Plans
• Make your voice heard!
• Comment period open until February 6, 2014
• Comment here:
http://www.regulations.gov/#!documentDetai
l;D=OSHA-2013-0023-0001

22. About Us
Simplifying a Complex World
Assured Services is a safety consultancy firm headquartered in Menomonee
Falls, Wisconsin.
We offer our expertise to improve outcomes through:
–
–
–
–
Strategic Planning
Risk Identification
Systematic Improvement
Workforce Development
Led by a National Safety Council award winning safety professional, we come
equipped with a strong passion for obtaining outstanding results.
info@assuredservicesllc.com
262.345.7955
www.assuredservicesllc.com