Do you have all the Safety records you need and are they up to date if OSHA or Cal/OSHA comes knocking on your door? If so, that’s great. If not, you need to get working on it because knocking on doors is exactly what OSHA plans on doing as part of their National Emphasis Program on Injury and Illness Recordkeeping, effective as of October 1st of this year (link here).

 

The intent of the program is to assess and evaluate the degree of under-reporting of workplace injuries and illnesses, which not only has been suggested by academic studies, but was also prominent in a report on the accuracy of employer worker injury and illness data, released by the GAO on Monday (link here).

 

Here are the key records you need:

 

1.    One of the unique requirements for California employers under Cal/OSHA is the need to “establish, implement, and maintain an effective Injury and Illness Prevention Program (IIPP).” Issues relating to the IIPP are the most often cited violation by Cal/OSHA and the key operative word should be considered maintain. Just having an IIPP filed in a binder is insufficient. Cal/OSHA won’t look at it kindly if it’s not being used as an active tool or employees don’t even know that it exists.

 

2.    OSHA Form 300, Log of Work-Related Injuries and Illnesses. Unless exempt (less than 10 employees, or in an exempt SIC code), employers are required to record all recordable or reportable injuries or illnesses on Form 300, along with a detailed incident report (Form 301 or equivalent).

 

3.    Annually posting the previous year’s Annual Summary of Work-Related Injuries and illnesses (Form 300A) from February 1 through April 30.

 

4.    Worker exposure records, including MSDS’s, environmental  & biological monitoring results, and other relevant records.

 

5.    Worker medical records created by doctors, nurses, and other healthcare personnel (dentists, therapists, etc.) that apply to the IIPP or to workplace injuries and illnesses.

 

Employers need to be able to make these records available on a timely basis to someone who has a right to request them, including employees, former employees, or OSHA & Cal/OSHA representatives.

 

Keeping records can be frustrating, confusing, and time-consuming, but it’s also important. Getting ahead of the curve and keeping records well-organized and well-maintained not only can help keep employers out of hot water with Cal/OSHA, but can also be used as a problem-solving tool.

Need help getting your IIPP or recordkeeping programs up to date? Not sure of where to start? If so, give us a call or send us an email. We’re here to help you succeed.