Reviewing OSHA's injury/illness recordkeeping rule
BackgroundOSHAâ€™s 2001 publication of Part 1904 actually completed a plan begun in 1994. In May of that year, the agency implemented a rule requiring employers to report fatalities and multiple hospitalization incidents orally to OSHA within eight hours of the incident.
Then, in March 1997, a second rule giving OSHA the authority to request injury and illness data from individual employers went into effect. That first year, OSHA sent letters to 80,000 general industry employers requesting injury and illness data. The 2002 data initiative requested the information from 93,000 â€” including 13,000 construction industry employers. OSHA uses this data for focusing inspections on employers with higher than average incidence rates. Companies with incidence rates of 14.0 or more receive a wall-to-wall inspection. The national average incidence rate for 2001 is 2.8.
Compared with the previous recordkeeping rule, the revised rule provides more detailed direction on how and when to record work-related injuries and illnesses. The requirements are presented in a question/answer format that incorporates many recording issues previously addressed in the â€œblue bookâ€ and interpretative letters.
Hearing loss and MSDsEven as employers began to record workplace injuries and illnesses in 2002 on new forms using new criteria, two issues â€” hearing loss and musculoskeletal disorders â€” had to be resolved.
A further change to recording hearing loss goes into effect on January 1, 2004, when employers will have a specific hearing loss column on the 300 Log to document these cases. This new column, (M)(5) â€œHearing loss,â€ is to be used for all recordable hearing loss cases, whether they are the result of the cumulative effects of high noise levels or the immediate loss of hearing caused by explosions or any other single-incident loud noise.
Year three â€” status quoWith the decisions relating to hearing loss and MSDs behind them, OSHA has no further major changes looming on the horizon for the recordkeeping rule. Rather, when issues arise that require recording direction, OSHA plans to issue clarifications via interpretative letters and revising its compliance directive, CPL 2-0.131. This directive, Recordkeeping Policies and Procedures Manual, outlines enforcement policies and procedures, penalty schedules, and answers many recordkeeping questions. It is available on OSHAâ€™s Web site at www.osha.gov.
SIDEBAR: Recordkeeping FAQsNew recordkeeping situations always arise that donâ€™t seem to have clearâ€“cut answers in the regulations. Here are clarifications that address some common recordkeeping issues: