What records need to be kept for OSHA compliance?

Every employer covered by OSHA who has more than 10 employees and is not exempt must maintain certain records of job-related injuries and illnesses. Three sets of routine records are required:

• OSHA Form 300, Log of Work-Related Injuries and Illnesses. This is not filed with the government unless it is requested, but should be kept on file at the worksite. It must be made available upon request of employees and OSHA compliance officers. Each recordable injury and illness must be entered on the log no more than seven calendar days after information is received that a recordable injury or illness has occurred. Preserve the forms for five years. See OSHA Form 300, Log of work-related injuries and illnesses at ¶11,320.

• Annual Summary, Form 300A. The Annual Summary, Form 300A, is a compilation of injuries and illnesses recorded on the OSHA 300 log during the previous calendar year. To prepare the Annual Summary, Form 300A, employers must review the OSHA Form 300 log entries to verify that they are complete and accurate. A copy of Form 300A and a worksheet that OSHA has prepared to help employers fill out the summary can be found at ¶11,320. A copy of the Annual Summary must be posted in each establishment in a conspicuous place where notices to employees are customarily posted. It must be posted by February 1 of the year following the year covered by the records and must be kept in place until April 30.

• OSHA Form 301, Injury and Illness Incident Report. An individual accident report must be available for inspection within seven calendar days of receiving information about a situation that is recorded on Form 300. It provides additional details about each injury or illness. Some insurance or workers' compensation forms can substitute for this form in order to avoid duplication. See OSHA Form 301, Injury and illness incident report at ¶11,320.

• Material Safety Data Sheets. These are created and distributed as part of comprehensive hazard communications programs. See Material safety data sheet at ¶15,430.

Exemptions. There are two exemptions from OSHA recordkeeping requirements. However, neither exemption excepts employers from OSHA coverage generally or from reporting fatalities and multiple hospitalization accidents. These employers also may be selected by the Bureau of Labor Statistics to participate in its annual survey of injuries and illnesses, which sets recordkeeping requirements similar to those of the OSHA log and summary.

The two exemptions are for:

• employers that had no more than 10 employees at any time during the preceding calendar year,

• employers in specified low-hazard industries.

Exempt categories are identified by Standard Industrial Classifications or SICs. Here is a list of currently exempt SICs:

• Security and commodity brokers, dealers, exchanges

• Auto dealers and gasoline service stations

• Apparel and accessory stores

• Furniture, home furnishings, and equipment stores

• Eating and drinking places

• Miscellaneous retail

• Banking

• Credit agencies other than banks

• Security and commodity brokers, dealers, exchanges and services

• Insurance

• Insurance agents, brokers, and service

• Real estate

• Holding and other investment offices

• Personal services

• Business services

• Motion pictures

• Legal services

• Educational services

• Social services

• Museums, art galleries, botanical and zoological gardens

• Membership organizations

• Private households

• Miscellaneous services.

Additional requirements. Many OSHA standards covering specific hazards or activities also set out recordkeeping requirements.