OSH Basics - General OSHA Recordkeeping and Posting Requirements

October 29, 2000

General OSHA Recordkeeping and Posting Requirements

The Occupational Safety and Health Act of 1970 requires most private sector employers to post certain information within the workplace and to prepare and maintain records of work related injuries and illnesses. These records include the OSHA Form No. 200, Log and Summary of Occupational Injuries and Illnesses, and the OSHA Form No. 101, Supplementary Record of Occupational Injuries and Illnesses.

Employers of 11 or more employees must maintain records of occupational injuries and illnesses as they occur. The purposes of keeping records are to permit survey material to be compiled, to help define high hazard industries, and to inform employees of the status of their employer's record. Employers in State plan are required to keep the same records as employers in other Federal OSHA Plans.

Injury and Illness Records and Reporting Requirements

Injury and illness recordkeeping forms are maintained on a calendar year basis. They are not sent to OSHA or any other agency. They must be maintained for five years at the establishment and must be available for inspection by representatives of OSHA, or the designated state agency.

Records That Must Be Kept

OSHA requires the use of OSHA Form No. 200, the Log and Summary of Occupational Injuries and Illnesses, or an equivalent form. On the OSHA Log, employers provide some brief descriptive information, and use a simple check-off procedure to maintain a running total of occupational injuries and illnesses for the year. Authorized federal and state government officials, employees, and their representatives are guaranteed access, upon request, to the injury and illness log for the establishment.

Employers are required to post an annual summary of occupational injuries and illnesses for the previous calendar year. The summary must be posted no later than February 1 and must remain in place until March 1.

OSHA Form No. 101 is used to provide supplementary information regarding each injury and illness entered on the log. This form names the person and describes the circumstances of his or her injury or illness. Substitute forms (such as workers' compensation reports) may be used if they contain all the specified information. Authorized government officials shall also be provided access to these records.

Injury and illness records shall be maintained at each workplace. In the absence of a regular workplace, records shall be maintained at some central location. The records shall be retained and updated for five years following the calendar year they cover.

OSHA recordkeeping is not required for certain retail trades and some service industries. Exempt employers, like nonexempt employers, must comply with OSHA standards, display the OSHA poster, and report to OSHA within 8 hours any accident that results in one or more fatalities or the hospitalization of three or more employees.

If an on-the-job accident occurs that results in the death of an employee or in the hospitalization of three or more employees, all employers, regardless of the number of employees, must report the accident, in detail, to the nearest OSHA office within 8 hours.

In states with approved plans, employers report such accidents to the state agency responsible for safety and health programs.

Be aware that many specific OSHA standards have additional recordkeeping and reporting requirements.

OSHA Posting Requirements

Employers are responsible for keeping employees informed about OSHA and about the various safety and health matters with which they are involved. Federal OSHA and states with their own occupational safety and health programs require that each employer post certain materials at a prominent location in the workplace. These postings include:

· Job Safety and Health Protection workplace poster (OSHA 2203 or state equivalent) informing employees of their rights and responsibilities under the Act. Besides displaying the workplace poster, the employer must make available to employees, upon request, copies of the Act and copies of relevant OSHA rules and regulations. Any official edition of the poster is acceptable.

· Summaries of petitions for variances from standards or recordkeeping procedures.

· Copies of all OSHA citations for violations of standards. These must remain posted at or near the location of alleged violations for three days, or until the violations are corrected, whichever is longer.

· Log and Summary of Occupational Injuries and Illnesses (OSHA No. 200). The summary page of the log must be posted no later than February 1, and must remain in place until March 1rst.

All employees have the right to examine any records kept by their employers regarding their exposure to hazardous materials, or the results of medical surveillance. Occasionally, OSHA standards or NIOSH research activities will require an employer to measure and record employee exposure to potentially harmful substances. Employees have the right (in person or through their authorized representative) to be present during the measuring as well as to examine records of the results.

Under these substance-specific requirements, each employee or former employee has the right to see his or her examination records. The employee must be told by the employer if exposure has exceeded the levels established by the standards. The employee must also be told what corrective measures are being taken.

In addition to having access to records, employees in manufacturing facilities must be provided information about all of the hazardous chemicals in their work areas in accordance with the OSHA Hazard Communication standard. Employers are to provide this information by means of labels on containers, material safety data sheets, and training programs at a minimum.

Continue to watch OSH Basics articles for an upcoming report on the OSHA Hazard Communication Standard. This future article will detail the requirements of this very important and often confusing OSHA requirement.

For official instructions on recording occupational injuries and illnesses please refer to the Recordkeeping Guidelines for Occupational Injuries and Illnesses, 1986. You may obtain copies of the Guidelines and OSHA forms by calling the OSHA Area Office or the State OSHA Office in your jurisdiction. You may also access the OSHA regulations from the OSHA web site at http://www.osha.gov/