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Recordkeeping 101: Part 1, Tracking injuries, illnesses puts you in control

By Brian Zaidman, Research Analyst, Research and Statistics, Minnesota Department of Labor and Industry. Reprinted from "Safety Lines: The Newsletter of Minnesota OSHA," Winter 2005.

For any business, no matter what size or type of activity it is engaged in, good business decisions should be based on accurate information. Thanks to the OSHA illness and injury log (OSHA Form 300), every business has a system for accurately recording and measuring one important aspect of workplace safety: the number of injuries and illnesses among its workers.

The OSHA log and its associated forms provide the tools needed by businesses to consistently measure injuries and illnesses over time and to compare performance with other companies in the same industry. Unlike many other business performance measures that are often created uniquely for each company, the OSHA recordkeeping system puts a ready-to-use tool into the hands of every business. Better measurement of safety means better ability to manage safety.

Only a little bit of effort is needed to ensure a company’s log is an accurate record of injuries and illnesses. One important prerequisite is training the staff members who are entrusted to maintain the log. For most people, browsing the resources currently available on the federal and state OSHA Web sites is adequate.

The U.S. Bureau of Labor Statistics (BLS) conducts an annual survey, the Survey of Occupational Injuries and Illnesses, collecting OSHA log data from a large sample of companies. Accurate injury and illness statistics allow a firm to compare its safety performance against that of similar firms in the state and nation. Such information can then be shared with workers, investors, customers and competitors to show the effectiveness of workplace safety programs that are in place.

The information can also be part of the effort used to earn special workplace safety status through Minnesota OSHA's Minnesota Safety and Health Achievement Recognition Program (MNSHARP) and Minnesota Star (MNSTAR) program.

The most recent version of the OSHA 300 log, the January 2004 revision, is available online as part of a federal OSHA recordkeeping package. Minnesota OSHA can also provide the proper form.

Although some companies use the log to record all workplace injury incidents, the final summary should be based only on those cases meeting the recordability criteria. Minnesota OSHA recordkeeping requirements, available online, contains recordkeeping requirements presented in a question-and-answer format to provide the details about OSHA log recordkeeping.

The basic recordkeeping requirement is that all work-related injuries and illnesses are recorded that result in: death, loss of consciousness, medical treatment beyond first aid, days away from work, restriction of work or transfer to another job. The following conditions must also be recorded when they are work-related:
  • a needlestick injury or cut from a "sharp" when contaminated with another person’s blood or other potentially infectious material;
  • any case requiring medical removal under an OSHA standard;
  • a tuberculosis (TB) infection as evidenced by a positive skin test or diagnosis when there is an exposure to a known case of active TB; and
  • a hearing loss as evidenced by a 25-decibel shift in hearing.
An injury or illness must be considered work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception, such as a choking injury while eating lunch or getting a case of the flu, specifically applies. The exceptions are listed on page 4 of Minnesota OSHA recordkeeping requirements.

Medical treatment is any treatment not included on OSHA’s first aid list and does not include visits to health care providers for observation only or diagnostic tests. (However, these visits may be covered by workers’ compensation insurance.)

The first aid list is discussed on pages 11 and 12 of Minnesota OSHA recordkeeping requirements. The procedures that are considered first aid are:
  • the use of nonprescription medication at nonprescription strength;
  • tetanus immunizations;
  • cleaning, flushing or soaking therapy;
  • wound coverings such as Band-Aids, gauze pads and butterfly bandages;
  • using hot and cold therapy;
  • nonrigid means of support;
  • using a temporary immobilization device to transport the victim;
  • drilling a fingernail/toenail or draining fluid from a blister;
  • use of eyepatches;
  • removal of foreign bodies from the eye if only irrigation or a cotton swab is required;
  • removal of foreign bodies from a wound, by tweezers, cotton swab or other simple technique;
  • fingerguards;
  • massages; and
  • drinking fluids for the relief of heat.
A complete understanding of the recordability criteria is presented in Minnesota OSHA recordkeeping requirements.

Resources:
Minnesota Safety Council Consultation, 651-291-9150/800-444-9150
OSHA Recordkeeping (Log 300 and 301 Training)
Department of Labor and Industry, Workplace Safety Consultation, 651-284-5060
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