The Most Common OSHA Recordkeeping Mistakes and How to Avoid Them

When an OSHA compliance officer arrives at your site for an inspection, one of the first items he or she will want to review is your injury log.  OSHA recordkeeping is an important aspect of your company's safety compliance and failure to handle this correctly can result in costly OSHA citations.  

Here are some of the most common mistakes employers make with OSHA recordkeeping: 

1. Failure to Retain OSHA Logs for 5 Years.  Under OSHA, records must be retained for five years.  In addition, your filed OSHA 300 Forms must be updated to reflect any new cases or reclassification of previously reported cases.
2. Failure to Properly Certify OSHA Logs.  A company executive must review the information provided on the OSHA 300 Form and verify that it is accurate and complete.   OSHA defines a company executive as one who "owns the organization, acts as an officer at the organization, is the highest ranking official working at the establishment or or the immediate supervisor of the highest ranking official."  So having the company safety manager sign may not satisfy the requirements, unless that person is also a company executive.
3. Failure to Post the OSHA 300A Form.  You must post your prior year's OSHA Form 300A, the annual summary, in a conspicuous area from February 1 until April 30 of each year.  This can be posted in your company's break room or lunch room.  
4. Failure to Accurately Describe the Injury or Illness.  You must provide a complete and accurate description of each injury or illness including the parts of the body affected, and the object or substance that injured the person.  Be as specific as possible.  For example, "cut on hand" is not specific enough.  A better description would state, "laceration on index finger due to contact with broken window glass".
5. Incorrect Case Classification.  The OSHA 300 requires you to check only one box to classify the case as either a death, days away from work, job transfer or restriction or other recordable.  However, many times an employer will check more than one box.  You should only check one box, and in cases where there is some overlap, you must check the box that reflects the most serious outcome of the case.  For example, if an employee had a recordable injury and missed days off from work, you would check the days off from work box.
6. Confusing Whether a Case is Reportable vs. Recordable.  All work-related injuries or illnesses should be reported following your company's internal procedures, but only those meet OSHA's definition for a recordable injury should be included in the OSHA injury log.  Your policy should require reporting of all incidents, including near-misses, injuries requiring firs-aid treatment only, and those occurring during voluntary participation in an activity.  The reported incidents should then be evaluated to determine whether they are recordable under OSHA.
7. Under and Over Reporting.  Your designated recordkeeper should be trained to appropriately recognize the types of incidents that must be recorded so that the incident date on your OSHA 300 reports is accurate and you avoid over and under reporting of injuries.
8. Failure to Record Significant Injuries & Illnesses Properly.  Certain injuries, such as cancer, chronic irreversible diseases, punctured eardrums, and fractured or cracked bones or teeth must be recorded on your OSHA logs regardless of the medical treatment and work instructions.  These types of injuries must be recorded when diagnosed.
9. Not Understanding that Workers' Compensation Laws and OSHA Recordkeeping Requirements Use Different Standards for Evaluating Injuries. Just because an incident is subject to a workers' compensation award, doesn't mean it is necessarily OSHA recordable.  Likewise, a denial of workers' compensation for an injury, doesn't mean you can omit the injury from your OSHA 300.