Just when employers had routine down and understood thedifference between an illness and an injury and what to report and record onthe OSHA 200 logs, the rules changed. Indeed on January 19th, 2001
the Occupational Safety andHealth Administration, OSHA, disseminated the changes of the new recordkeepingrequirements, forms, and definitions. The implementation date for compliance byemployers is January 1st 2002
.Written information may be contained on the new requirements of OSHA’s website.OSHA’s recordkeeping requirements have been implemented since 1971 and werecreated to help employers identify workplace hazards and correct conditionshazardous to employees by maintaining records and tracking injuries, illnesses,and their causes. The new rule has been created to simplify the record keeping systemand the use of technology for employees. The revisions provide betterinformation about occupational illnesses and injuries and their causes.Emphasis is also being placed on better production of an employee’s privacy.
Let’s begin by looking at the three new forms to be used inthe new recordkeeping requirements. Previously the 200 log was used to trackwork place injuries and illness. The new form is called the OSHA Form 300. Thesecond new form is the OSHA Form 301 referred to as the injury and illnessincident report. This new form replaces the old OSHA Form 101, and will includemore data about how the injury or illnesses occurred. Read the self-explanatorydirections to complete the OSHA Form 301. Examples are provided to guide therecord keeping in properly completing the details of the information about howthe illness or injury occurred. Additionally, a requirement for the employer tobe aware of is the posting of the final new form OSHA Form 300A, formerly knownas summary of injuries and illness, or the Form 102. Previously Form 102 was postedfor 1 month. The OSHA Form 300A must be signed and certified by a companyexecutive and posted from February 1 to April 30 for three months. Highlightsof the additional changes include:
1) Whatset of criteria to be used for determining whether an injury or illness is tobe recorded
2) Definitionsof key terms such as First Aid, Medical Treatment, and Restrict Work have beenchanged. Under the new rule the employer will be required to report cases whenan injury or ill employee’s normal duties performed regularly at least once aweek are restricted
3) Amongthe eliminated key terms and definitions is Lost Work Days replaced by newterms such as Days Away, or Days Restricted. Days Away or restricted duty wouldbe based on calendar days instead of scheduled work days for the affectedemployee. Employers are required to establish a procedure for employees torecord injuries and illnesses and to inform employees of the procedure to befollowed. In addition a criteria for deciding when mental illnesses are consideredwork related has been added. There is also special recording criteria formedical removal under OSHA standards for cases involving the work relatedtransmission of tuberculosis.
The new rules and requirements mayundoubtedly cause confusion for many employees. The time to start investigatingrecord keeping requirements and obligations is now. This program will provideinformation and explanation for the new OSHA Form 300 and other new forms.
Let’s begin by viewing the firstof the three forms titled OSHA Form 300, log of work related injuries andillnesses. Now let’s work through each of the line items listed. Let’s begin bylooking at the top left hand side of the form that identifies the OSHA Form300. Please read the boxed section explanation beginning with the bold word.Attention: This form contains information relating to employee health and mustbe used in a manner that protects the confidentiality of employees to theextent possible while the information is being used for occupational safety andhealth purposes. Please complete the information on the right hand corner. Thisis the line for the year the form is being completed, and when the injuries orillnesses occurred. Beneath the top heading is written information for the criteriaand instructions to complete the record keeping required, and guidance to the additionalforms to be used for recording and reporting to OSHA. On the right sidecomplete the establishment name.