Following the rules

Recent action by the Occupational Safety and Health Administration makes this a good time to evaluate your company’s record keeping procedures and incident goals.

OSHA has rewritten its Record Keeping Rule for Occupational Injury and Illness Recording and Reporting to clarify the recording of workplace injuries and illnesses. Business owners should determine how they may be impacted by the reporting requirements of the new rule, which goes into effect Jan. 1, 2002.

While the final rule contains most of the provisions originally proposed by OSHA, two significant ones have been delayed until Jan. 1, 2003: the definition of musculoskeletal disorders and specific reporting requirements for occupational hearing loss.

Most of the changes are either administrative or meant to help clarify the determination of whether an incident is “recordable.” However, a change in the manner in which lost workdays are counted (the counting rule) may significantly impact your company’s safety goals.

Under the new rule, lost workdays are counted in terms of the number of calendar days an employee is away from work, not just the number of workdays. With this system, 2002 lost workday rates may be higher than 2001 rates.

Any company that measures its safety performance by tracking lost workdays should familiarize itself with the standard changes and consider modifying its 2002 performance goals.

Major changes that may result in additional new cases and could account for an increase in the number of lost workdays or restricted days include:

  • The addition of “significant injury or illness” diagnosed by a physician or licensed health care provider to the recordable requirement. Significant injuries or illnesses, such as chronic diseases that result from a work exposure, would become recordable at the time of diagnosis, even though no lost time or restricted duty may have occurred.
  • Provisions for needle stick injuries, privacy concern cases (for example, blood-borne pathogen cases), medical removal cases such as elevated blood lead levels, tuberculosis, and temporary and contract employees have been added to the rule.
  • “Days away from work” and “days of restricted duty” for injuries and illnesses are calendar days now rather than scheduled workdays. The total days are counted regardless of holidays, vacations, weekends or work schedules. This will minimize the confusion of counting days but may increase the overall days logged.

Some other changes:

  • The current 200 and 101 forms will be replaced with forms 300, 300A and 301, which are more straightforward and easier to complete.
  • The new rule includes a list of specific situations that are not considered work-related, such as commuting, personal consumption of food and drinks, voluntary participation in recreation and personal tasks.
  • A list of 14 medical treatments considered not recordable first-aid treatment is included. The use of nonprescription medications, steri-strips, massage and hot or cold therapy are four of the first-aid treatments identified. All other medical treatment is still considered recordable.
  • The length of time the annual summary must be posted has been extended by two months. Currently, employers only need to post the summary for the month of February. Now, it must be posted from February through April.
  • A requirement has been added to help ensure the participation of employees in the program review process.
  • Low hazard industries that are exempt from record keeping requirements are identified in an appendix.

The new forms and instructions for completing them can be found on OSHA’s Web page at

Dianne Grote Adams, a board certified industrial hygienist, board certified safety professional and certified professional environmental auditor, is president of Emilcott/DGA (, an environmental, industrial hygiene and safety consulting company in Westerville. She can be reached at (866) 364-5342 or by e-mail at [email protected].