Here’s a bit of news you should know: Federal OSHA just changed the rules. Before, it required the work-related hospitalization of three or more injuries to be reported to OSHA. Now, a single workplace injury resulting in an in-patient hospitalization, an amputation, or the loss of an eye requires reporting to OSHA within 24 hours by calling 800-321-6742 or by calling the closest OSHA Area Office. As always, any work-related fatality requires reporting within 8-hours. The updated rule went into effect on January 1, 2015.
Federal OSHA discusses the reporting change above, as well as changes to its 1904 Recordkeeping and Reporting Requirements page that is accessible at https://www.osha.gov/recordkeeping/.
Employers in State Plan OSHA States
As always, however, employers located in State Plan OSHA States should check to see if their own state follows the Federal OSHA recordkeeping and reporting requirements or whether their State Plan OSHA may have even stricter requirements.
Difference Between Reporting and Recordkeeping
Let’s dig a little deeper on these changes. First of all, to understand the changes, it is important to distinguish between federal OSHA’s recordkeeping requirements and its reporting requirements.
Reporting, such as required by the changes that took effect on January 1, refers to instances when an employer must reach out to contact federal OSHA to make them aware of an incident that has occurred in the workplace. Healthcare facilities are affected by these updated reporting changes if a work related fatality or certain other incidents were to occur in their workplaces.
Recordkeeping refers only to the maintenance of certain required records. Those records are simply maintained by the employer, but they do not have to actually be reported or sent to OSHA, unless OSHA, for some reason, asks an employer for them. OSHA’s recordkeeping changes are simply additions and removals to the list of who has to keep the required records, and healthcare facilities are not impacted by the recordkeeping changes.
OSHA presently requires, and will continue to require, certain employers to maintain what are called the OSHA 300 series of recordkeeping forms:
OSHA 300 Log of Work-Related Injuries and Illnesses
OSHA 301 Injury and Illness Incident Report
OSHA 300A Summary of Work-Related Injuries and Illnesses.
In addition to the above three forms, employers covered by the Bloodborne Pathogens Standard must also maintain the following form as well:
Sharps Injury Log.