Poor record keeping is one of the top OSHA citations each year . Billboard Insider talked with Formetco’s Safety Director Jim Poage to learn what record keeping requirements OSHA expects from out of home companies.
What is the OSHA requirement for record keeping?
Employers are required to keep accident, illness, and injury logs on employees through out the year. These logs are required to be kept up to within two weeks of any occurrence and must document the employee affected, what type of injury or fatality occurred, days away from the job, and if there was a temporary reassignment of job duties. Every year from February 1 to April 30 the summary of the log must be posted in a conspicuous location so that all employees are aware of the previous year’s injuries. On May 1st, the posting can come down and must be filed for future review by OSHA if there is ever a record request made. You can find these documents at the OSHA.gov website listed as the 300 and 300A forms.
Also, if there is a change in an employee’s status, such as they die from an injury after the year the documents were created, the employer is expected to go back and amend that year’s records to reflect the updated change.
I thought there was an exemption for the advertising industry from having to keep OSHA logs.
There are a couple of partial exemptions to keeping OSHA injury and illness records such as employers who had ten or fewer employees at all times during the previous calendar year, and companies that have the NAIC code 54185 for Display Advertising. OSHA uses the term “partial exemption” because even though there is a reduced recordkeeping requirement, OSHA still requires these employers to report within 24 hours of occurrence any fatality or in-hospitalization of employees.
Even though the federal OSHA requirements may exempt certain employers from keeping accident, illness, and injury records, some state plans may still require it. I advise checking with local OSHA offices to ensure you are complying with local requirements.
Is a COVID illness required to be recorded on the 2021 OSHA Log?
Possibly. OSHA has said that if an employee test positive for COVID by a test method approved by the Food and Drug Administration, the event or exposure is confirmed to have occurred in the work environment, and it must meet the other general recording requirements. The general requirements for recording are in hospitalization, death, missed workdays, or reassignment of job duties due to the virus.
How long do I need to keep OSHA accident logs?
OSHA requires five past years of records to be kept on file, plus the current year.
How important are these records?
Jim: These are the first records an OSHA will ask for when they walk in the door of any business to begin an inspection. Recordkeeping is always one of the top citations issued by OSHA every year.
What if I’m unsure about an incident being recorded?
I have always advised that if you are unsure, record the incident anyway, then draw a single line through it so it can still be read. This way, if there ever is an investigation you can show that you weren’t negligent in recording, and that you lined it out because you weren’t sure if it was an actual recordable incident. You can get assistance on this by calling your Worker Comp insurance carrier or asking a safety person to help.
Want to learn more about how Formetco can help you to maintain a safe workplace. Contact JimPoage@formetco.com, 602-951-1132.
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