MNOSHA Compliance: Recordkeeping standard

New:  COVID-19 and recordkeeping

• Federal OSHA:  Revised enforcement guidance about recording cases of coronavirus disease 2019 (COVID-19)

Minnesota OSHA (MNOSHA) Compliance follows federal OSHA recordkeeping guidance, which is used across the country and needs to be consistent for national data comparison, with the exception that in Minnesota, low-hazard industries are also required to record injuries and illnesses.

MNOSHA Compliance will enforce the recordkeeping requirements of 29 CFR Part 1904 for all employers with employee COVID-19 illnesses. Recording a COVID-19 illness does not, of itself, mean the employer has violated any OSHA standard. And, pursuant to existing regulations, employers with 10 or fewer employees have no recording obligations; they need only report work-related COVID-19 illnesses that result in a fatality and report any employee's in-patient hospitalization, amputation or loss of an eye.

More information about COVID-19 is available from federal OSHA and from the Centers for Disease Control and Prevention.

Recent injury reporting changes made by federal OSHA adopted or to be adopted by Minnesota OSHA

• 1904.35, 194.36 and 1904.41:  Improve tracking of workplace injuries and illnesses; final rule – Minnesota OSHA (MNOSHA) has adopted this final rule, see Rulemaking news – MNOSHA adopts federal regulations. For more information, call MNOSHA at 651-284-5050.

• Note:  The Survey of Occupational Injuries and Illnesses is a separate program from the OSHA electronic reporting program. To learn more about the differences in these programs, read One log, two data collection programs (page 11) in the July 2018 edition of Safety Lines.

• Changes to OSHA's injury reporting rule became effective Oct. 1, 2015.

• Changes to OSHA's recordkeeping requirements (for low-hazard industries) were not adopted by Minnesota OSHA, which is consistent with past requirements in Minnesota.

Free training about the basics of OSHA recordkeeping offered in September, October

Maintaining an accurate OSHA log of recordable work-related injuries and illnesses is an important skill that benefits employers, workers, safety professionals and government agencies. The Department of Labor and Industry (DLI) offers free introductory-level training seminars about OSHA recordkeeping requirements.

Topics

• Recordability of injuries and illnesses

• Differences between OSHA cases and workers' compensation claims

• Classifying cases

• Counting time

• Privacy cases

• How many logs to keep

• Maintaining logs

• Creating a log summary

• Reporting log data to OSHA

• Recording COVID-19 cases

Dates, locations

• Sept. 25, 8:30 to 11:30 a.m. (webinar, online only) – registration required

• Oct. 2, 8:30 to 11:30 a.m. (webinar, online only – registration required)

Registration is required

• Register now (There is no cost to attend.)

For more information, email dli.research@state.mn.us.

About recordkeeping

OSHA log cases are not the same as Minnesota workers' compensation claims. Some injuries and illnesses will not be included in both systems.

The federal OSHA recordkeeping and reporting occupational injuries and illnesses standard is effective in Minnesota, with the exception of 1904.2, Partial Exemption for Establishments in Certain Industries.

Under the standard, employers must use OSHA Form 300, Log of Work-related Injuries and Illnesses, and Form 300A, Summary of Work-related Injuries and Illnesses. Additionally, employers must keep a record of each incident that appears on the log, using the OSHA Form 301, Injury and Illness Incident Report, or the workers' compensation First Report of Injury form.

• Complete instructional packet for Forms 300, 300A, 301 and instructions (PDF) (XLS)

The annual summary for the previous year, OSHA Form 300A, must remain posted from Feb. 1 through April 30.

Further information is available on the federal OSHA website at www.osha.gov/recordkeeping.

Note:  The OSHA forms are not designed for printing on standard 8.5" x 11" paper and should be printed on legal-sized paper, if possible.

Recordkeeping 101

• Part 1:  Tracking injuries, illnesses puts you in control

• Part 2:  Classifying recorded injuries

• Part 3:  The days of our cases

• Part 4:  Tell me what happened; describing the event

• Part 5:  Injury or illness?

• Part 6:  Summarizing the injury and illness log

• Part 7:  Using your log results:  'How do we compare?'  |  Rate chart (Excel)

• Part 8:  A guide for keeping an accurate OSHA log

Recordkeeping 201

• Part 1:  Privacy concerns -- when not to write a name

• Part 2:  Records access, information disclosure

• Part 3:  Job transfer and restricted work

• Part 4:  New or deja vu? When to record injury recurrences and episodic illnesses

• Part 5:  Needlesticks and sharps injuries, contact with bodily fluids

• Part 6:  What are 'other recordable cases'?

• Part 7:  A close look at first aid

• Part 8:  'And a one, and a two' -- Counting employees and hours

• Part 9:  Matching workplaces and workers to OSHA logs

• Part 10:  Recording cases and reporting claims -- A tale of two systems

Industry-specific recordkeeping information

• Fabricated metal product manufacturing

• Hospitals

• Nursing homes