Employers are required to document and record a large number of issues, events and programs that take place at their workplace. Thorough documentation allows employers, workers and OSHA inspectors to evaluate the safety of a workplace, understand its hazards better, and take steps to prevent injuries and illnesses.
But it’s important to note that safety recordkeeping requirements differ for injuries, training, inspections, emergency plans and SDSs.
What records are relevant to health and safety?
Health and safety folks also talk about “recordables”, which is the colloquial name given to injuries that are significant enough to require being recorded. But there are other records employers have to keep that are relevant to health standards, including:
- written programs and procedures
- program reviews
- medical surveillance
- industrial hygiene monitoring
- exposure records
- hazard evaluations
Although the connection between written programs and physical health is not immediately obvious, any of the above can have an impact on the work environment, performance and employee safety.
With certain exceptions, most organizations that employ more than ten people have to keep a record of serious work-related injuries and illnesses, which OSHA specifically defines as:
- work-related fatalities—these must be reported by the employer within 8 hours;
- work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job;
- work-related injury or illness requiring medical treatment beyond first aid; or
- work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
There are also special recording criteria for work-related cases involving needlesticks and sharps injuries, medical removal, hearing loss and tuberculosis. Additionally, amputations, loss of an eye, or hospitalization of a worker has to be reported by the employer within 24 hours.
Minor injuries needing only first aid are not required to be recorded. However, OSHA’s definition of first aid doesn’t always match the employer’s understanding of it. For example, removing foreign bodies from the eye using irrigation or a cotton swab is considered first aid by OSHA. However, performing the same action with a magnetic foreign body remover is not considered first aid and needs to be recorded. Differences like this make it plain that employers have to understand the recordable regulations well to follow them correctly. As a best practice, keep a record of all first-aid treatments even if the injury is not significant enough to be a reportable recordable.
Another issue to remember is the employer’s responsibility to post an annual summary of injuries and illnesses recorded at their workplace in the previous year. As of 2017, many employers have been able to do this online on a website provided by OSHA.
Record-keeping can be confusing. For example, some records need to be kept for 30 years or more (medical records and exposure records of workers exposed to toxic substances or blood-borne pathogens, as well as SDSs or other records of the identity of the substances or agents to which employees were exposed). Some documentation (such as workplace injuries) has to be kept for five years and yet other records (such as government compliance records) have to be kept only for four years.
Considering all of the above, it’s important to know what employers need to keep and for how long. Moreover, the documentation has to be available to employees or OSHA inspectors, which means the records need to be easily accessible. This is why it’s worth being mindful of changing technology and the constant updates to computer programs, software and electronic forms.
Employers have to realize that their records need to withstand all of these changes. But any system (computerized spreadsheets, personnel files, specific programs, etc.) is acceptable as long as it’s effective.
And “effective” means that the required information is readily available. It’s easy to check if a system is effective by considering the following scenario: if the person responsible for the files is not present during an OSHA inspection, can the requested documents be found? If the answer is yes, then the system is most likely effective.
When it comes to employees’ medical information, employers should not possess specific findings or diagnoses unrelated to occupational exposure such as medical history, medications, blood pressure or respiratory protection medical evaluations.
Instead, employers should have written opinions based on medical evaluations. Such opinions do not share specific results, but instead have information such as: “worker can/can’t perform their duties” or “can perform their duties with following limitations…” Employees’ confidentiality of medical records is vital.
If you’re unsure what needs documentation and for how long, look at the end of each standard where you should find information on recordkeeping, training, program reviews and inspections. But when in doubt, it’s a good idea to keep everything. If, for example, you perform an accident investigation, keep any photos, measurements, diagrams, interviews and other material produced during the investigation.
Document your safety program and keep all policy materials, procedure manuals and information distributed to employees (e.g., memos, safety handbooks, other training materials and safety meeting minutes). Keep medical records and documentation required by workers’ compensation, insurance and safety audits, and any government inspections.
Finally, employers should make sure that all their documentation is legible, complete, and up to date. Even the fullest cabinet or the latest data storage program are not going to be helpful if they’re not used properly and the documentation is incomplete or out of date.