Recordkeeping: Is THAT Recordable?

Injury on job site man helping coworker walk

Safety data and metrics are invaluable performance indicators for employers. Recording and mapping the variety of incidents, events, and initiatives creates powerful insights for companies to leverage. But not all data is equal and not all records should be recorded and reported the same way.

There are specific sets of records that are more important for employers than others. These are the recordables that OSHA specifies need to be tracked and logged by employers operating within any of the industries OSHA deems as a “covered industry”. Some companies may feel that they can skirt around these requirements by either not recording the data points as outlined or skewing the numbers when the time comes. This is an ill-advised maneuver, though, as OSHA can request to verify records at any time and a failure to do so will result in severe penalties and fines. And as the adage goes, “better safe than sorry.”

Which Recordables Are Most Important?

Keeping track of every possible data point related to safety and health will quickly overwhelm any employer. This is why employers need to focus their efforts on the most relevant recordables to cover themselves and their employees.

The primary injury and illness recordables as determined by OSHA are:

  • Any work-related fatality.
  • Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
  • Any work-related injury or illness requiring medical treatment beyond first aid.
  • Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
  • There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.

OSHA requires in the following instances that injuries not only be recorded, but in addition the employer must reach out to contact OSHA and report the injury:

  • Employers must report any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization of a worker within 24 hours.

Some of the definitions in the recordables above can also trip up employers. Companies must familiarize themselves with how OSHA specifically defines certain terms when it comes to recordables. This is because these differing definitions will have a major impact on how and where some recordables are recorded.

For instance, OSHA draws a hard line between “first aid” and “medical treatment”. The way OSHA defines first aid is very specific and a full list of criteria is available on their recordkeeping page. One such example that could potentially trip up employers while reporting is that removing a splinter or foreign material from areas of the body using simple means is considered “first aid”. But removing a splinter or foreign material from the eyes specifically is a “medical treatment”.

Other Types of Recordables

It’s also important that employers keep records detailing the extent of their safety programs even though these recordables are not posted or reported in the same way as injury recordables. This is necessary to validate that employers conform to OSHA requirements regarding the training and certifications for specific standards. Each standard has certain safety training requirements that slightly differ from standard to standard — such as some requiring PPE training or Forklift training — but most require the same general safety training records.

Employers should record the following for each employee to ensure they are meeting required recordkeeping objectives:

  • Past training on the same safety topic
  • The next scheduled training date
  • Summary of training content (objectives, key training points, etc.)
  • Reason for nonscheduled retraining (for example, an accident or deterioration in safety performance)
  • Safety orientation dates for new employees and orientation program content

Should This Be Recorded?

The answer for employers asking this question is “probably”. Employers can verify per standard what needs to be recorded and what doesn’t. But the best tactic for employers in doubt to utilize is that it is better to keep a record rather than not keep of record of safety information. The one caveat to this general rule is employee health information. Employers should not retain or possess specific medical findings, diagnoses, or medical history except as they relate to direct occupational exposure. This is to protect employee confidentiality and privacy.

Recordkeeping is like most other details with OSHA in that it can be very complicated to sort through without help. This is why our team of health and safety professionals at Amerisafe Group offers OSHA Recordkeeping Workshops to help when navigating the ins and outs of compliance and OSHA-related documentation. The dates for Amerisafe’s OSHA Recordkeeping Workshops vary throughout the year – if you’re interested in learning more, please click here to inquire about the next open workshop dates and availability.

No employer wants to be caught unaware or non-compliant when OSHA arrives. However, teaming with the safety experts at Amerisafe provides a partner with detailed safety experience to guide employers through every aspect of working with OSHA.

Amerisafe Group provides the information and services to help companies develop safety leaders and improve overall safety performance. For more information on how we can assist with your businesses’ occupational health and safety needs, contact an expert today.