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
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
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
Records That Must
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
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
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.
Employee Rights to Exposure Monitoring Records
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.
FOR MORE INFORMATION
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/
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