osha log recordkeeping

10-3-201210-3-2012 11

OSHA LOGOSHA LOGRecordkeepingRecordkeeping

Brian ZaidmanBrian Zaidman

Senior Research AnalystSenior Research Analyst

Minnesota Dept. of Labor and IndustryMinnesota Dept. of Labor and Industry

MN Dept of Labor & IndustryMN Dept of Labor & Industry

10-3-201210-3-2012 22

Goals of PresentationGoals of Presentation

General recordkeeping reviewGeneral recordkeeping review Recording needlesticks, Recording needlesticks,

exposures and infectionsexposures and infections Special recordkeeping topicsSpecial recordkeeping topics


10-3-201210-3-2012 33MN Dept of Labor & IndustryMN Dept of Labor & Industry

10-3-201210-3-2012 44

The not so Secret Key to The not so Secret Key to recordkeeping successrecordkeeping success

Read the instructions that come in the log Read the instructions that come in the log packetpacket

Read the log before you begin filling it outRead the log before you begin filling it out If you don’t understand something, ask If you don’t understand something, ask

someonesomeone If you need training, get trainingIf you need training, get training If someone asks you for recordkeeping If someone asks you for recordkeeping

training, approve it immediatelytraining, approve it immediately


10-3-201210-3-2012 55

Is an injury or illness Is an injury or illness recordable?recordable?

““recordable” means countable as an injury recordable” means countable as an injury or illness case of sufficient severity to merit or illness case of sufficient severity to merit inclusion in the loginclusion in the log

Completely separate from workers’ Completely separate from workers’ compensationcompensation Even if your workers’ comp insurer denies a Even if your workers’ comp insurer denies a

claim, it still might be a recordable caseclaim, it still might be a recordable case


10-3-201210-3-2012 66

Recordable if:Recordable if:

Work-related Work-related injury or illnessinjury or illness Time away from work, job restriction or Time away from work, job restriction or

transfer, or transfer, or medical treatment beyond medical treatment beyond first aidfirst aid

Loss of consciousnessLoss of consciousness Not a recurrence of an ongoing chronic Not a recurrence of an ongoing chronic

conditioncondition


10-3-201210-3-2012 77

Recordkeeping: Worker and Recordkeeping: Worker and injury/illness descriptioninjury/illness description

NameName OccupationOccupation Date of eventDate of event Location of eventLocation of event Event and injury descriptionEvent and injury description

Can use multiple lines in formCan use multiple lines in form


10-3-201210-3-2012 88

Describing injury and illness Describing injury and illness casescases

Activity worker engage inActivity worker engage in Nature of injury (what)Nature of injury (what) Part of body injured (where)Part of body injured (where) Source(s) of injury (object or substance)Source(s) of injury (object or substance) Event or exposure (how)Event or exposure (how)


10-3-201210-3-2012 99

Case classificationCase classification

FatalityFatality Day away from workDay away from work Job transfer or restrictionJob transfer or restriction Other recordableOther recordable Not recordableNot recordable


10-3-201210-3-2012 1010

Needlesticks and Sharps Needlesticks and Sharps injuriesinjuries

Must be a contaminated objectMust be a contaminated object Blood or potentially infectious materialBlood or potentially infectious material

Record as an injury (column M)Record as an injury (column M) Do not enter worker’s nameDo not enter worker’s name

Use “Privacy concern case”Use “Privacy concern case”

If no time away from work or restrictions, If no time away from work or restrictions, then this is an “other recordable” casethen this is an “other recordable” case


10-3-201210-3-2012 1111

Needlesticks and Sharps Needlesticks and Sharps injuries injuries (cont.)(cont.)

If the worker later is diagnosed with an If the worker later is diagnosed with an infectious bloodborne diseaseinfectious bloodborne disease Update log to indicate illnessUpdate log to indicate illness Change description to include type of illnessChange description to include type of illness Change case classification, if neededChange case classification, if needed


10-3-201210-3-2012 1212

Immunizations and Immunizations and InoculationsInoculations

Not recordable unless a work-related injury Not recordable unless a work-related injury or illness has occurredor illness has occurred

If in response to a needlestick or exposure If in response to a needlestick or exposure to bloodborne pathogen, then case is to bloodborne pathogen, then case is already recordablealready recordable

Worker must first test positive for exposure Worker must first test positive for exposure or infection for a non-needlestick/sharps or infection for a non-needlestick/sharps incident to be recordableincident to be recordable


Tuberculosis casesTuberculosis cases

Must record whereMust record where1)1) Worker has been exposed in the workplace Worker has been exposed in the workplace

to anyone with an active TB caseto anyone with an active TB case

2)2) Worker subsequently develops a TB Worker subsequently develops a TB infectioninfection

Classified as a respiratory infectionClassified as a respiratory infection Date of illness is the date of diagnosisDate of illness is the date of diagnosis

10-3-201210-3-2012 MN Dept of Labor & IndustryMN Dept of Labor & Industry 1313

10-3-201210-3-2012 1414

Privacy concern casesPrivacy concern cases

ONLY use “Privacy concern case” forONLY use “Privacy concern case” for Injuries to intimate body parts or reproductive Injuries to intimate body parts or reproductive

systemssystems Injury or illness resulting from sexual assaultInjury or illness resulting from sexual assault Mental illnessMental illness


10-3-201210-3-2012 1515

Privacy concern cases Privacy concern cases (cont.)(cont.)

ONLY use “Privacy concern case” forONLY use “Privacy concern case” for HIV infection, hepatitis or TBHIV infection, hepatitis or TB Contaminated needlesticks and cuts from Contaminated needlesticks and cuts from

sharp objectssharp objects Other illnesses, if worker independently and Other illnesses, if worker independently and

voluntarily asksvoluntarily asks

These are the ONLY allowable usesThese are the ONLY allowable uses


10-3-201210-3-2012 1616

Privacy concern cases Privacy concern cases (cont.)(cont.)

Can also be vague about description to help Can also be vague about description to help protect worker’s identifyprotect worker’s identify Gender and job titleGender and job title

Keep a separate list that matches name to Keep a separate list that matches name to each caseeach case Used for updating informationUsed for updating information May be needed by OSHAMay be needed by OSHA


10-3-201210-3-2012 1717

OSHA log exampleOSHA log example

Review cases entered on handoutReview cases entered on handout


10-3-201210-3-2012 1818

OSHA log maintenanceOSHA log maintenance

Maintain log for 5 years following end of Maintain log for 5 years following end of calendar yearcalendar year

Update information if cases changeUpdate information if cases change Do not need to update summaryDo not need to update summary


10-3-201210-3-2012 1919

Re-injury and recurring casesRe-injury and recurring cases

A chronic illness case is only recorded A chronic illness case is only recorded once if workplace exposure is not needed once if workplace exposure is not needed for signs or symptoms to recurfor signs or symptoms to recur

To be a new case, worker needs to have To be a new case, worker needs to have completely recovered from the previous completely recovered from the previous illnessillness

If symptoms triggered by workplace If symptoms triggered by workplace exposure, must record as a new caseexposure, must record as a new case


10-3-201210-3-2012 2020

Relation to workers’ compensationRelation to workers’ compensation

OSHA recordkeeping requirements are OSHA recordkeeping requirements are different from WC lawsdifferent from WC laws

An injury may be counted in one system An injury may be counted in one system and not in the otherand not in the other

Each system has its own system for Each system has its own system for determining work-relatednessdetermining work-relatedness

Some workers not covered by WC are Some workers not covered by WC are considered employees for OSHAconsidered employees for OSHA


10-3-201210-3-2012 2121

Recordkeeping: Final thoughtsRecordkeeping: Final thoughts

Recordkeeping can be complicatedRecordkeeping can be complicated Needs to be consistent, comparable and Needs to be consistent, comparable and

correct to be usefulcorrect to be useful Review your site’s log information Review your site’s log information

regularly, keep it accurateregularly, keep it accurate Use available resources to maintain Use available resources to maintain

record qualityrecord quality


10-3-201210-3-2012 2222

Contact Brian by:Contact Brian by:

E-mail: [email protected]: [email protected] Phone: 651-284-5568Phone: 651-284-5568 DLI Research and Statistics Web site: DLI Research and Statistics Web site:

http://www.dli.mn.gov/Research.asp Or show up in personOr show up in person


osha log recordkeeping

Documents