Employer responsibility for workplace safety goes beyond training employees on safe work habits, providing personal protection equipment and following procedures established in OSHA standards. The Occupational Safety and Health Act of 1970 also requires employers to track injuries and illnesses sustained on the job, and gives the Occupational Safety and Health Administration authority to set recording parameters. Although OSHA exempts some businesses from the paperwork recording requirement, it expects every private-sector employer to report deaths, injuries resulting in hospitalization, eye losses and amputations within a specific time frame.
Determining What Is Work-Related
When an employee has an injury or illness, the employer must determine if it is work-related. If it is, OSHA treats it as an event that must be recorded. Not all employee injuries merit recording: A retail employee who gets injured after returning to the store to shop after her shift does not have a work-related injury under OSHA's definition. Telecommuters injured while working at home may have a recorded injury if, according to OSHA, "the injury or illness is directly related to the performance of work rather than to the general home environment or setting." Tripping over the family pet, for example, doesn't meet this definition, but smashing a finger in a file cabinet drawer does. For employees on business trips, OSHA considers hotels "homes away from home" and exempts off-duty time in them.
If an employee aggravates a pre-existing condition due to exposure to a hazard at work, her injury is a work-related event that needs to be recorded when any of these apply:
- Unconsciousness not previously suffered
- New or different medical treatment necessary
- Time off or reduced working hours required
Having determined an event is work-related, employers then compare the circumstances surrounding it against OSHA criteria outlined in its Standards 1904.7 through 1904.12 to confirm the need to record it on OSHA Log 300.
OSHA uses four basic criteria to qualify a work-related injury or illness that needs to be recorded:
- Causes death
- Causes absence from work, activity restriction on the job, or moving the employee into another position
- Requires more than first aid treatment
- Causes unconsciousness
If a licensed health care professional diagnoses an employee's work-related illness or injury as "significant," OSHA wants employers to record it in the 300 Log even when none of the four basic criteria is present. They also must report work-related punctures from sharp objects or needles contaminated by blood, perforated eardrums, and illnesses such as tuberculosis and cancer.
Finally, employers must use OSHA's definition of first aid to conclude that any necessary medical treatment makes a work-related injury reportable.
Some work-related safety events also require employers to call OSHA within a certain number of hours: fatalities, serious injuries that result in in-patient hospitalization, amputations and eyeball loss. Again, OSHA definitions come into play as the agency does not consider hospital admission for tests or observation to be in-patient hospitalization. Amputations include partially severed body parts that physicians reattach and fingertips. Although loss of sight may be an injury that needs to be recorded, it is not one that needs to be reported; only loss of the eye, defined by OSHA as removal of the eyeball, must be reported.
Good communication enables an employer to comply with the OSHA reporting mandate. The reporting clock starts to tick as soon as an employer learns an employee has one of the four reportable events. OSHA wants a call within eight hours of a death that happens 30 days or fewer after a work-related injury. The agency gives employers only 24 hours to report an eye loss, in-patient hospitalization and amputation that results from an on-the-job accident.
Employers call OSHA at 800-321-OSHA, or their nearest OSHA area office, unless they operate in a state or U.S. territory that runs its own OSHA agency. In addition to designating a contact person's name and number, reporting employers tell OSHA the incident type and provide a brief description that includes time, place and the number of employees involved.