Enjoy paperwork? If OSHA’s recordkeeping standard, bloodborne pathogens standard and process safety management standard apply to you, that means maintaining four different OSHA injury and illness logs.

1) OSHA injury & illness recordkeeping

If your entire corporation or entity had more than ten full- or part-time employees at any time last year, and you are not in one of the exempt Standard Industrial Classifications (SIC), then you are required to keep an OSHA 300. {1904.1(a)(1)}

Even if you are covered by one of these two exemptions, you may still be required to keep the OSHA 300 if you receive the Annual Survey from the Bureau of Labor Statistics or direction from OSHA. You would receive this at the beginning of the year for which you would need to keep these records.

You must use the OSHA Form 300 that is provided by OSHA or a form with the same information.

2) Privacy concerns

If you are required to maintain an OSHA 300, certain recordable injuries and illnesses must be recorded on the OSHA 300 without entering the employee’s name or providing information that would identify who received the injury or illness. These cases are called Privacy Concern cases. {1904.29(b)(6)} Privacy concern cases include:

• Injury or illness to an intimate body part. That hasn’t been defined specifically as yet, but you have an idea of what that may include.
• Injury or illness resulting from sexual assault.
• Mental illness.
• HIV infection, hepatitis, or tuberculosis.
• Needlestick injuries and cuts from sharp objects that are contaminated with potentially infectious material.
• Any other illnesses if the employee requests that his or her name not be entered on the OSHA log.

These cases, when recordable, must be entered on the OSHA 300, but the words “Privacy Case” would be placed in column B of the OSHA 300 in lieu of the employee’s name. If stating the employee’s job or type of injury would identify the employee, those entries should be camouflaged.

For privacy concern cases, a separate list must be kept that includes the case number and the employee’s name. Only medical personnel and OSHA have a right to review the privacy concern list.

3) Needlesticks & sharps injuries

On January 18, 2001, OSHA amended the Bloodborne Pathogens standard — 1910.1030 — at paragraph (h)(5) to require a “Sharps Injury Log,” separate from and in addition to the OSHA injury and illness 300, for employers who are required to maintain the OSHA 300 described in the first section of this article. This log is required for percutaneous (this is a $5 word that means “penetration of the skin”) injuries from sharps and needles that are contaminated with potentially infectious materials as defined in the bloodborne pathogens standard at 1910.1030(b).

You can use an OSHA 300 modified to record the required information or just a spreadsheet with the following information:

• The type and brand of device involved in the incident;
• The department or work area where the exposure incident occurred;
• An explanation of how the incident occurred.

The identity of the employee is required to be kept confidential on this log also. Since you’ve already recorded the same case on the OSHA 300 and the privacy concern log, you might use some type of simple code on the Sharps Injury Log to relate these cases back to the information on the privacy concern log and the OSHA 300.

If you keep your OSHA 300 electronically, then being able to sort the OSHA 300 into sharps cases and non-sharps cases would be suitable. If you keep your OSHA 300 on paper, OSHA states that a separate page of the 300 for sharps cases would be necessary.

It’s important to note here that these three logs discussed thus far must be kept up-to-date for five years following the year in which the injury occurred.

4) Process safety management

In the Process Safety Management standard at 1910.119(h)(2)(vi), a separate log of work-related injuries and illnesses that occur to contractor employees in an area of the facility covered by this standard must be maintained.

For example, if a contractor employee loses consciousness due to breathing chorine while on your premises, and the chorine cylinder is a standard one ton size cylinder, then the contractor’s injury will be recorded on his/her employer’s OSHA 300 (assuming that the contractor is not directly supervised by you), and the injury will also be recorded on your contractor log of injuries and illnesses.

(NOTE: The contractor would record this case on its OSHA 300 regardless of the size of the cylinder because a work-related loss of consciousness occurred. But if the cylinder is less than 1500 pounds, the host employer would not be covered by the process safety management standard because the threshold quantity for coverage when the chemical is chlorine is 1500 pounds.)

The standard itself is not clear about the applicability of this paragraph. For example, does it apply to just OSHA recordable cases, or does it also apply to first aid cases? Does it apply to an organization that is covered by 1910.119, but exempt from 1904?

Paragraph 1910.119(h)(1) provides some guidance by stating that the log must be kept by “contractors performing operating duties, maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process area. It does not apply to contractors providing incidental services that do not influence process safety, such as janitorial work, food and drink services, laundry, delivery or other supply services.”

Further guidance can be found in the preamble to this standard in the February 24, 1991, Federal Register on page 6387 at the bottom of column 2. OSHA states “an employer should be informed of all of the injuries and illnesses occurring in processes involving highly hazardous chemicals at the plant.”

The purpose of this rule is to help an employer identify incidents that occur in a process area so that root causes can be determined and future incidents prevented. With that purpose in mind, I recommend that you record all work-related injuries and illnesses, recordable or first aid, that occur to any contractor in the process areas regardless of cause. Best practice is to have a separate log of all contractor injuries and illnesses that occur on your site.

SIDEBAR: Reasons for keeping records

An event that requires recording on all four logs is quite unlikely and keeping these logs will not be much of a burden. Don’t lose sight of the reason behind all of these rules: to help safety and health professionals identify hazards and implement controls. So go ahead and enjoy the paperwork!