Recordkeeping &
Reporting: How the
Revised Standard
Affects Industry
History of the Regulations
In place since 1971
Proposed changes announced in February
1996 (“The Revision of the Injury & Illness
Recordkeeping System”)
Revision announced on January 18, 2001
Final rule published in Federal Register on
January 19, 2001
Final rule effective January 1, 2002
What are the regulatory
requirements?
OSHA regulations address:
 Occupational injury and illness
recording
 Occupational injury and illness
reporting
Applicable regulations:
 29 CFR 1904
 29 CFR 1952
What is the purpose of the
regulations?
Provide employers with a tool for tracking
and recording workplace illnesses and
injuries
Aid employers with recognizing workplace
hazards and correcting hazardous
conditions
Allow OSHA to track trends in safety
What prompted revisions to the
regulations?
Industry complaints
 Former recordkeeping requirements were
complicated
 Former recordkeeping forms were
cumbersome
Confusing regulations
 Former regulations included only
requirements
 Interpretations were found in many forms
What prompted revisions to the
regulations? (continued)
Former regulations did not include
provisions for needlestick and sharps
injuries
Former regulations included complicated
criteria for reporting musculoskeletal
disorders (MSDs)
OSHA attempting to revise, update, and
simplify all regulations
Who is subject to the
regulations?
All employers subject to the OSH Act
Exempt from most requirements: Industries
classified as low-hazard sectors
 e.g., Retail, service, finance, insurance, and real estate
 List revised to reflect recent industry illness/injury data.
Excluded from full reporting requirements:
 Religious establishments
 Household employees performing ordinary domestic
tasks
 Certain volunteers
Who is subject to the
regulations? (continued)
Excluded from full reporting requirements:
(continued)
 Industries classified under SIC codes 52-809,
except codes 52-54, 70, 75, 76, 79, and 80
 Small businesses (10 or less employees)
 Sheltered workshops and job training programs
(unless personnel are compensated)
 Stockholders (unless employed by the corporation
in which they hold stock)
 Self-employed persons
Primary Improvements to the
Standard
Better definition of work-related injuries
Clarified definition of restricted work
Provisions for improved employee
awareness and involvement
 Provides workers or their representatives
access to the information on recordkeeping
forms
 Increases awareness of potential hazards in
the workplace
Provisions for employee privacy
Primary Improvements to the
Standard (continued)
“Plain English” wording
Question and answer format
Inclusion of checklists and flowcharts
Inclusion of interpretations as well as
requirements
Simpler forms
Flexibility for using computers to meet
requirements
Summary of Key Provisions to
New Recordkeeping Rule
Updated recordkeeping forms
 OSHA Form 300: Log of Work-related Injuries
and Illnesses
 Replaces Form 200: Log and Summary of
Occupational Injuries & Illnesses
 Simplified reporting requirements
 Printed on smaller legal sized paper
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Updated recordkeeping forms (continued)
 OSHA Form 301: Injury and Illness Incident
Report
 Replaces Form 101: Supplementary Record of
Occupational Injuries & Illnesses
 Includes more data about how injury or illness
occurred
 OSHA Form 300A: Summary of Work-related
Injuries and Illnesses (easier calculation of
incident rates)
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Eliminates different criteria for recording
work-related injuries and work-related
illnesses
 New rule uses one set of criteria for injuries
and illnesses.
 Former rule required employers to record all
illnesses, regardless of severity.
 New rule accounts for severity of illness.
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Requires records to include any workrelated injury or illness resulting in:
 Death
 Days away from work
 Restricted work or transfer to another job
 Medical treatment beyond first aid
 Loss of Consciousness
 Diagnosis of a significant injury/illness by
licensed health care professional
Note: Exposures in and of themselves are not
recordable.
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Includes new definitions to simplify
recording decisions
 Medical treatment
 First aid
 Restricted work
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Requires a significant degree of workrelated aggravation before a pre-existing
injury or illness becomes recordable
Includes separate provisions describing
recording criteria for cases involving
work-related transmission of tuberculosis
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Add additional exemptions to the
definition of work-relationship
 Limits recording of cases involving
eating/drinking food beverages
 Limits recording of common colds and flu
 Limits recording of blood donations
 Limits recording of exercise programs
 Limits recording of mental illness
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Clarifies recording of “light duty” or
“restricted work” cases
 Requires employers to record cases when
injured/ill employee is restricted from normal
duties
 Defines normal duties: duties the employee
performs at least once weekly
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Conforms with new ergonomics standard
 Requires employees to record all needlestick
and sharps injuries involving contamination
by another person’s blood or body fluids
 Applies same recording criteria to MSDs as to
all other injuries and illnesses
 Revised recordkeeping forms have separate
column for recording MSDs
 Employers retain flexibility to determine
whether an event or exposure in work
environment caused or contributed to MSD
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Requires employers to record standard
threshold shifts (STS) in employees’
hearing
 Defines STS: an adverse change in an
employee’s hearing threshold, relative to
his/her most recent audiogram
 Requires recording hearing loss cases at 10
dB shift, rather than 25 dB shift
 Provides a separate column on Form 300 to
capture statistics on hearing loss
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Changes regarding lost/restricted work
 Change in terminology
 Eliminates “lost workdays”
 Focuses on “days away” or “days restricted or
transferred”
 Includes new regulations for counting days
 Rely on calendar days instead of workdays
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Changes to employer requirements
 Employers must establish procedure for
employees to report injuries and illnesses
 Employers must tell employees how to report
 Employers are prohibited from discriminating
against employees who report
 With change of ownership, seller must turn
over OSHA records to buyer
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Changes to employee rights
 Privacy rights
 Prohibits employers from entering an individual
employee’s name on Form 300 for certain types of
injuries/illnesses
Sexual assaults
HIV infections
Mental illness
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Changes to employee rights (continued)
 Privacy rights
 Provides employers the right not to describe the
nature of sensitive injuries where the employee’s
identity would be known
 Gives employee access to portions of Form 301
relevant to the employee they represent
 Requires employers to remove employees’ names
before providing data to persons not provided
access under the rule
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Requires the annual summary to be
posted for three months (Feb. 1 to April
30) instead of one
Requires certification of annual summary
by a company executive
Changes reporting of fatalities and
catastrophes to exclude some motor
carrier and motor vehicle incidents
Allows all forms to be kept on computer
equipment or at alternate location
General Impact of Changes
Final rule anticipated to impact
approximately 1.3 million establishments
 Some changes will increase number of
recordable cases; some will decrease number
 OSHA anticipates roughly same number of
reported injuries/illnesses
Newly exempt industries will experience
reduced costs
General Impact of
Changes (continued)
Newly covered industries will experience
additional costs and benefits
 Must learn new requirements
 Must revise computer systems used for
recordkeeping
Areas of Potential Cost Savings
Form 300: Less time to complete simpler
forms
Exemptions from the requirement to
consider certain cases work-related (will
result in less cases being recorded)
Elimination of different recording criteria
for injuries and illnesses (will result in less
cases being recorded)
Areas of Potential
Cost Savings (continued)
Changes to the requirements for recording
illnesses and injuries with days away or
job restriction/job transfer (will result in
less cases being recorded)
Changes to the criteria for recording cases
of tuberculosis (will result in less cases
being recorded)
Changes to the criteria for recording
fatality/catastrophe incidents (will result in
less cases being recorded)
Areas of Potential
Cost Savings (continued)
Elimination of separate recording criteria
for MSDs (will result in less cases being
recorded)
Improvement in determining recordability
of illness/injury
Allowance of computerized and
centralized records
Areas of Potential Cost Increases
Form 300A
 Requires increased employer review of data
and additional data on the average
employment/hours worked at establishment
 Changes result in higher quality data, but
more time and cost to employer
Changes to the definitions of medical
treatment and first aid (will result in more
cases being recorded)
Areas of Potential
Cost Increases (continued)
Change to the criteria for recording cases
of hearing loss (will result in more cases
being recorded)
Change to the criteria for recording
needlestick and sharps injury (will result
in more cases being recorded)
Increased employee involvement
Employee privacy protections
Benefits of the Revised
Regulations
More accurate data regarding
occupational illnesses and injuries
Simplified overall recordkeeping systems
for employers
Better protection for employees’ privacy
“The revision… will not lessen an employer’s
recordkeeping responsibilities, but it will make it
easier to successfully meet the requirements.” —
Sec. of Labor, Alexis Herman
Resources for Additional
Information
 Web site: www.osha.gov
 OSHA Region IV (Alabama, Florida, Georgia,
Mississippi): 404-562-2300
 29 CFR 1904: Occupational Injury and Illness
Recording and Reporting Requirements
 “The Blue Book”: Recordkeeping Guidelines for
Occupational Injuries and Illnesses
 Available from OSHA
 Last updated in 1991