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OSHA Recordkeeping

NEW OSHA RECORDKEEPING STANDARDS EFFECTIVE 1/1/2002

Mike Haberman

On January 1, 2002 new OSHA recordkeeping standards go into effect. This new standard requires the use of three new forms and it changes several definitions. This standard is 29 C.F.R. 1904, and it requires the use of three new forms and changes the definitions of several areas that have an effect on what is to be recorded.

There are several exemptions from compliance with this new standard. First, employers with fewer than 10 employees throughout all times of the last calendar year do not have to keep OSHA injury or illness records. Secondly, companies that are classified in certain SIC codes also do not have to keep OSHA injury or illness records. (To determine if your company is exempt by SIC code click this link below to view the list. http://www.osha-slc.gov/OshStd_data/1904_New/1904_0002.html) However, in both exemptions, companies must report to OSHA an incident that results in a fatality or the hospitalization of three or more employees.

The new forms consist of the OSHA Form 300, Log of Work-related Injuries and Illnesses; OSHA Form 300A, Summary of Work-related Injuries and Illnesses; and OSHA Form 301A, Injury and Illness Accident Report. The Form 300 replaces the current Form 200 and the Form 301 replaces the current Form 201. Form 300A is a new form that simplifies calculation of incident rates. Additionally, a company executive must also sign this form. (For further information click on this link below. http://www.osha-slc.gov/OshStd_toc/1904_New/OSHA_Std_toc_1904_SUBPART_C.html)
Additional changes include:

• Changes in the definitions of illness, aggravation of pre-existing condition, parking lot accidents and mental illness.


• Recordable days change from work days to calendar days.


• A new definition of restricted work.


• A new list of First Aid activities.


• A new concern for Privacy.


• The posting requirement changes to 90 days.

You should be aware of these changes since the recordkeeping requirement starts on January 1st. However, the Form 200 must still be posted by February 1, 2002 and remain posted until March 1, 2002.