OSHA Injury & Illness Recordkeeping Requirements

OSHA has (again) partially exempted certain industries from regular injury and illness recordkeeping on OSHA forms 300 and 300A.  While certain healthcare practices are included in the list of such industries, the Bloodborne Pathogens Standard, state laws and pending interpretations may still require recordkeeping of all work-related injuries and illnesses.  Therefore, we recommend continuing to maintain these records, as usual, to ensure compliance.

Small employers (i.e., fewer than 10 employees at all times during the previous year), regardless of industry classification, continue to be exempt from routinely recording work-related injuries and illnesses on OSHA forms 300 and 300A.  However, certain severe injuries and illnesses, as well as needlestick and other sharps injuries that involve occupational exposure to blood or other potentially infectious materials, must still be recorded.

OSHA has also issued a new list of severe injuries and illnesses that must be directly reported (to OSHA) within specified time periods of their occurrence.

Please refer to the article in the upcoming December Advisor for detailed information.