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Clearing Up the Confusion on OSHA Reporting

Dana Vorholt is Sentinel’s safety and loss control guru. His official title is Director of Risk Management

The questions, calls and emails come like clockwork to my inbox at the start of every new year, from clients concerned they might miss something relative to their federal OSHA reporting requirements. First, it’s important to establish that the OSHA reporting requirement pertains to all companies who have more than 10 employees and are not on the exemption list. Let this serve as a friendly reminder that it is your responsibility to post injuries and incidents if you haven’t yet.

Rather than see OSHA reporting as a pesky task that takes valuable time, I recommend that you see it as an opportunity to be transparent about your organization’s losses, as well as an opportunity to benchmark 2019’s losses against prior years. In short, are there exposures or areas you can mitigate losses via analyzing the data you have compiled?

There is also a fair amount of confusion over which injuries or incidents are “recordable” or not. In some instances, a lack of understanding or simply the lack of frequency handling injuries or illnesses within the workplace can lead to over (or under) reporting on their OSHA Log. A great resource that can be helpful for all companies and organizations when determining recordability is the OSHA Recordkeeping Advisor tool, available here on the administration’s website. This tool will assist you in determining, with a high degree of certainty, the path you need to take for reporting.

And since record keeping standards can change from year to year, I encourage Sentinel clients to contact me prior to the February reporting deadlines if they are unsure how to interpret enacting language. The most recent change is aimed at protecting worker privacy. OSHA has rescinded the requirement for establishments with 250 or more employees to electronically submit information from OSHA Forms 300 and 301. It should be noted that the impacted establishments are still required to maintain these records onsite for purposes of inspections and enforcement activities. Additionally, submission of the Form 300A is still required. If your establishment falls in this size of operations and isn’t on the recordkeeping reporting exemption list, please note the particulars of the granular level amendment changes on OSHA’s website, here.

North Carolina has seen an uptick in workplace fatalities since 2017, with 53 recorded deaths in 2019, up from 40 in 2017. Those numbers do not include traffic accidents, homicides and suicides, which fall outside of OSHA’s jurisdictional authority. The construction industry continues to lead the state in fatalities, representing 20 of the 53 fatalities reported in 2019. It’s important to note that despite the rise in fatalities, North Carolina is enjoying historic low numbers of job-related injury and illness overall.

And lastly, the state Department of Labor is pushing workplace safety measures for construction, manufacturing and other high-risk industries, with their National Safety Stand-Down to Prevent Falls campaign slated for the first week in May. The campaign is a voluntary program for employers to talk directly to employees about fall awareness and safety.

Any workplace can hold a stand-down, simply by taking a break to focus on fall hazards and reinforcing the importance of fall Prevention. If your company doesn’t have a specific fall exposure to discuss, this can serve as a great opportunity to have a conversation with your employees about other job hazards encountered on the job, protective safety protocols, and specific safety policies and goals.

Read more about the NC Department of Labor’s safety campaign here.