Recordkeeping: It's More Than Just Compliance

There are many good reasons for keeping thorough and up-to-date records of accidents and injuries that occur on the job. The primary reason, of course, is compliance with the law. But a thorough reporting and recordkeeping system can also provide you with valuable information concerning accident patterns and prevention. Being able to observe injury and illness trends in the workplace over a span of time helps identify shortfalls or omissions in training, and allows an opportunity to strengthen the overall safety of the workplace.

When to Record

The Occupational Safety and Health Administration (OSHA) requires most employers to maintain OSHA records for all “OSHA recordable” injuries and illnesses. Employers meeting the requirements for a small-employer exemption or who are engaged in what are known as a “partially exempt industry” may be exempt from maintaining these records. For employers who do not meet those exemptions, injuries and illnesses must be recorded if they:

• Involve an employee.
• Are work-related.
• Are a new case, meaning that the employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body or that the employee previously experienced such an injury or illness, but completely recovered.
• Result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
• Are a significant work-related injury or illness that is diagnosed by a physician or other licensed health care professional.
• Result from a needlestick injury or a cut from a sharp object that is contaminated with another person’s blood or other potentially infectious material.
• Result in the medical removal of an employee under the medical surveillance requirements of an OSHA standard.
• Involve occupational hearing loss.
• Involve an occupational exposure to tuberculosis and subsequent development of the infection.

Organizations regulated by OSHA are required to maintain a log (OSHA Form 300) and an annual summary (OSHA Form 300A) of occupational injuries and illnesses, as well as a supplementary record of each recordable injury or illness (OSHA Form 301). These records must be kept up to date and must be made available to OSHA and the National Institute for Occupational Safety and Health (NIOSH) on request. You must retain them on file for at least five years.

State laws often also require you to keep safety and health records and to file reports. Workers’ compensation laws, for example, may require accident reports.

Even if an employer is not required to maintain records, it is still a good idea to do so.

Accident Reporting and Prevention

In addition to complying with the law, a thorough reporting and recordkeeping system can also help you prevent future accidents. For example, studying these records can reveal areas in which accidents are on the increase, safety procedures that have brought the best results, and even new approaches to accident prevention.

Above all, the process of conducting an accident investigation and filling out a written accident report focuses attention on what has occurred, thus forcing your safety management team to consider what might have been done (or could be done) to avoid the incident.

Most accident reports focus on uncovering and recording the vital facts and circumstances surrounding an accident as soon as possible after it has occurred. These “key facts” usually include:

• Nature of the injury.
• Part of the body injured or affected by the injury.
• Source of the injury: the object, substance or bodily motion that produced the injury.
• Type of accident or manner in which the person was injured.
• Hazardous condition or circumstances surrounding the accident.
• Agency of the accident: the object, substance, or part of the premises in which the hazardous condition existed.
• Unsafe act that caused or permitted the accident to occur.

These items not only enable supervisors and safety committees to fill out the required report forms, but also help your organization evaluate the progress of your safety or accident-prevention program. If additional safety training or changes in procedures and equipment are needed, the investigation and reporting process usually makes it clear exactly what should be done.

Of course, in order to report or document workplace injuries and illnesses, the employer needs to be aware when they occur. Minor injuries often go unreported by employees for various reasons, such as embarrassment or fear of discipline.

Setting Recordkeeping Policy

Without an effective policy, your accident reporting procedures might fail to meet requirements, and be much less effective in identifying trends or training needs. Your policy must be understandable, consistently applied and enforced in order to be effective.

The following elements are critical to an effective accident reporting policy:

Purpose. Stress not only legal compliance but also the value of reports in preventing future accidents.

Definition of “accident.” Be specific so that those responsible for reporting know exactly what types of accidents must be reported. Encourage the reporting of “near misses” as well, since such incidents are often the precursor to more serious accidents and injuries.

Reporting procedures. Include a brief summary of the information that should be reported (who, what, when, where, how, why), where forms can be obtained, how soon the report must be completed, and other relevant requirements. Consider “short form” methods for reporting safety concerns or near misses that result in no damage or injury, and would not otherwise require the completion of a more formal report.

Drug testing. If your drug-testing policy requires tests after certain accidents, your accident forms and policies should be coordinated with your drug-testing policy.

Documentation. Attach copies of accident report forms to the policy statement and describe any special certification required.

Responsibilities. Stress the importance of the supervisor’s role in reporting accidents, getting medical help for injured employees, filling out report forms, etc. If you have a safety committee, talk about its role in accident reporting and investigation.

Confidentiality. Make sure your policy sets out confidentiality requirements and procedures for employee medical information. Keep accident reports separate from personnel files to protect confidential information. In order to foster employees’ willingness to report minor injuries, accidents or near misses, it is very important that confidentiality of witness reports be protected as well. Anonymous reporting might be considered, but understand that follow-ups would be difficult, if not impossible, should insufficient information be provided.

Workers’ compensation. Accident reports are often required for workers’ compensation insurance. These forms should also be completed when accidents are reported.

Potential litigation. Be sure to also cover the manner in which the report should be maintained, distributed, and written if there is a potential for litigation. You want to avoid a situation in which an accident report admits liability and is used in future litigation against you. Include only known facts, and avoid inserting opinion, hearsay or conjecture.

The Bottom Line

There is a lot more to recordkeeping and reporting of accidents than simply satisfying OSHA regulations. The reports serve to protect both the company and the employees when used as a tool for prevention and training. The information obtained is useful for follow-up training or the regular updating of safety procedures and policy. Maintaining an understandable, coherent reporting system that is used to enhance safety in the workplace can increase employee confidence that their safety matters to their leadership. This, in turn, fosters a greater buy-in and strong safety culture.

Ed Sterrett, CPP, is a professional safety and physical security consultant and founder of Central Florida Safety Academy, based in Orlando.

Republished with permission. © 2013 Ed Sterrett. All rights reserved.​