Injury & Illness Recordkeeping

The Occupational Safety and Health Act requires most private sector employers to prepare and maintain records of work-related injuries and illnesses. Originally issued in 1971, the regulations are ultimately designed to help employers recognize workplace hazards and correct hazardous conditions in order to enhance the overall safety of the workplace. OSHA also uses workplace injury and illness data and information to develop new safety and health rules and standards, to evaluate the overall effectiveness of the Administration’s enforcement program, and for directing OSHA’s program activities, including scheduled workplace inspections and non-enforcement initiatives, such as targeted mailings of safety and health information.

In 2001, OSHA issued its long awaited revisions to the workplace injury and illness recordkeeping requirements. Such revisions made numerous changes, including making the requirements applicable to janitorial service providers for the first time (i.e.: building service contractors) and requiring the use of new recordkeeping forms.

What Standards Apply?

OSHA: Recording and Reporting Occupational Injuries and Illnesses 29 CFR 1904

What Does the Standard Require?

The OSHA Workplace Injury and Illness Recordkeeping Standard requires that non-exempt employers with more than 10 employees at any time during a calendar year record each injury, illness and fatality that (1) is “work-related;” (2) is a “new case;” and (3) meets general or specified recording criteria.

An injury or illness is “work related” if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Further, an injury or illness is a recordable “new case” if the injured employee had not previously experienced and recorded an injury of the same type to the same part of the body or the employee had recovered completely from a previous injury or illness of a similar nature.

An injury or illness meets the “general recording criteria” if it results in death, days away from work, restricted work or transfers to another job, medical treatment beyond first aid, or a loss of consciousness. OSHA has also established particular recording criteria for a number of specific types of injuries and illnesses that may occur in the work environment, including needlestick and sharps injuries.

In addition to the recording requirements addressed above, employers must also report to OSHA any workplace incident that results in the death of a worker or the in-patient hospitalization of three or more employees. Such a report must be made within eight hours of the incident and must be made by telephone or in-person.

What Are the Common Hazards and Solutions?

Workplace injuries and illnesses are an unfortunate reality. Workers in the cleaning industry may be exposed to potentially hazardous chemicals, may be asked to work with equipment that can present a danger and may be asked to perform various tasks that may unintentionally cause an injury or illness. Musculoskeletal injuries can occur when an employee does not take the proper precautions when engaging in various physical activity and exposure to chemicals can result in numerous health effects, including skin and eye irritation, respiratory difficulty and heart and kidney ailments. Further, the exposure to blood and other potentially infectious material can result in infection and other serious diseases, while walking surfaces in disrepair can lead to slip and fall accidents.

The injury and illness recordkeeping regulations are designed to help employers recognize workplace hazards and correct hazardous conditions before injuries and illnesses occur. By documenting the incidents that do occur in the workplace, an employer will be better suited to identify trends and take necessary corrective and preventive action.

Documenting workplace injuries and illnesses also raise the awareness of the employees, themselves. Employers are required to post an annual summary of injuries and illnesses in a conspicuous place where employee notices are customarily posted. The annual summary must be posted no later than February 1 of the year following the year covered, and must remain posted until April 30.

Employers are also required to ensure that workers and their representatives are involved in injury and illness recordkeeping in a number of ways. For example, employers must ensure that a method is established for employees to report injuries and illnesses promptly and must provide open employee access to all records that do not involve a “privacy case” (access must also be granted to all former employees).

Additional Resources