Those of us in the industry tasked with record-keeping sometimes struggle with all of the different reporting scenarios. OSHA 29 CFR 1904, “Recording and Reporting Occupational Injuries and Illness,” gives us guidelines, but even the most thorough research of compliance requirements can still lead to questions and confusion.
For example, workers’ compensation cases may not be recordable as OSHA cases due to exceptions in the agency’s record-keeping rules. Workers’ compensation is mandated by each state, while OSHA 1904 is a federal record-keeping standard.
Further, OSHA’s record-keeping standard was updated in 2002, at which time many changes were made, including some that made the standard easier to understand but others that made it more difficult. Additional changes were made effective January 1, 2015. While basic reporting has essentially remained the same over the years, it’s important to be aware of the 2015 change found at 1904.39(a)(2), which states, “Within twenty-four (24) hours after the in-patient hospitalization of one or more employees or an employee's amputation or an employee's loss of an eye, as a result of a work-related incident, you must report the in-patient hospitalization, amputation, or loss of an eye to OSHA.” These requirements were added to provide OSHA insight on less serious injuries in certain industries that typically have a higher incident/DART rate.