S. Amir Kohan

OSHA – Recordkeeping Requirements

OSHA regulations require that records be kept for many purposes. It is necessary to conduct and document inspections of the workplace, looking for safety and health hazards. It is necessary to document and make available to employees records about hazardous materials and how they must be properly handled. Employers with ten or more people on the payroll must summarize all injury and illness instances and post that summary in a conspicuous place within the workplace. That report must remain posted from February 1 to April 30 each year. Certain employers are exempt from some OSHA recordkeeping requirements. They generally are classified by industry Standard Industrial Classification (SIC) code. A list is available on OSHA’s website at www.OSHA.gov. Any time there is a serious or fatal accident, a full incident report must be prepared by the employer and maintained in the safety file. These records must be maintained for a minimum of 5 years from the date of the incident. Known as a log of occupational injury or illness, it must include a record of each incident resulting in medical treatment (other than first aid), loss of consciousness, restriction of work or motion, or transfer or termination of employment. If you are in the medical industry, construction industry, or manufacturing industry, or you use nuclear materials of any kind, there are other requirements you must meet. The key to compliance with OSHA rules is communication with employees. Training is often provided by employers to meet this hazard communication requirement. In summary, then, OSHA recordkeeping involves the following:

• Periodic safety inspections of the workplace
• Injury or illness incident reports
• Annual summary of incidents during the previous calendar year
• Injury and illness prevention program (if required by rules governing your industry)
• Employee training on safety procedures and expectations
• Records of training participation
• Material safety data sheets for each chemical used in the workplace (made available to all employees in a well-marked file or binder that can be accessed at any time during work hours)


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