Does your recordkeeper know the OSHA regs?

By: Travis Rhoden

Publication: Workplace Safety Regulatory Alert

Date Posted: 08/20/2020

Training in OSHA recordkeeping requirements

According to a recent Bureau of Labor Statistics (BLS) survey, many companies who keep OSHA injury and illness logs have never trained the person who is in charge of the logs.

Training in OSHA recordkeeping requirements is designed to increase recordkeepers’ knowledge of the kinds of injuries and illnesses that should be recorded and what information recordkeepers are required to include about those cases. This training intends to increase the quality of the information that employers record in OSHA logs.

For respondents who indicated that OSHA logs were kept at their establishment or firm, the Respondent Survey asked if the person primarily responsible for OSHA recordkeeping had ever received formal training such as classes, seminars, or online courses. Around one-half (48 percent) of the establishments reported that the person primarily responsible for OSHA recordkeeping had received formal recordkeeping training. About the same percentage of establishments (46 percent) responded that their employees had not received formal training.

Work-related “personal task” exception

Recordkeepers often misapply the “personal task” exception. It only applies if the injury occurred (1) while the employee was engaged in a personal task, AND (2) outside assigned working hours. OSHA does not consider lunch or break time when determining assigned hours. For example, if one employee loans another a lawn mower, and the two workers go outside during lunch to move it from one truck to the other, any injuries would be work-related because they are within working hours. But, if the workers moved the mower after their shift, it would not be work related for recordkeeping purposes.

A majority of establishments in the utilities (92 percent) and information (87 percent) sectors reported that their primary recordkeeper had received formal training. Construction was the only sector in which a majority of establishments (83 percent) indicated that the primary recordkeeper had never received formal training. Of the establishments who indicated that their employees had received formal OSHA recordkeeping training, a higher percentage (66 percent) said that the training had last occurred between 1 and 5 years than any other period prior to the Respondent Survey. Only 12 percent reported that the recordkeeping training had occurred in the previous year.

What OSHA Recordkeepers Need To Know

About the author
Travis Rhoden - EH&S Editor

Travis is a senior editor with J. J. Keller & Associates, Inc. He specializes in safety management systems, job hazard analysis, machine guarding, storage rack safety, forklift training and OSHA inspections. 

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