OSHA recordkeeping is an essential responsibility for employers, and mistakes can result in costly OSHA citations. However, OSHA regulations are complex, and errors or misunderstandings are bound to occur. That’s where your expertise as an agent can really shine.
Open Doors & Protect Your Book With OSHA
Helping your clients with OSHA is a huge value added to your relationship, as it could save them significant money and frustrations. Use these top OSHA recordkeeping mistakes in two ways to support your clients:
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- Education: Send them this list to equip them to avoid these mistakes as they handle day-to-day OSHA recordkeeping. Get a downloaded version of this list to deliver it professionally.
- Consulting: Go one step further by offering to review your clients’ OSHA logs to identify if any of these mistakes were potentially made. You can use this opportunity to remind them about the March 2 submission deadline if they are required to submit electronically to OSHA.
Don’t stop there—use these same strategies to open doors with prospects. Send them these tips, and offer a free review of their OSHA logs. It’s a great way to build an initial relationship on trust and value, making you the logical agent of choice.
Below are the most common mistakes employers make (...and how to fix them).
1. Supervisors aren’t trained to encourage reporting
The last thing you want is an OSHA citation for discouraging employees from reporting injuries or worse, retaliation. Make sure your managers and supervisors are trained to understand your employee reporting policies and procedures—and that they all take a pro-safety, pro-reporting attitude with their teams.
2. Too much reliance on your workers’ comp agency
If your work comp carrier denies a claim because it is not “work-related,” that doesn’t necessarily mean you don’t need to record it. OSHA’s definition of work-relatedness may be broader than your work comp agency.
3. You record every incident that occurs
You may think you’re covering all your bases by recording every injury, illness, and near-miss that occurs—even if it doesn’t meet OSHA recordkeeping criteria. However, doing so may unintentionally result in a higher incident rate, making you a target of an OSHA inspection. Be thorough and act in good faith, but only document what is required.
OSHA defines a work-related case as one where a workplace incident or exposure caused or contributed to the condition, or “significantly aggravated” a pre-existing condition.
4. Temporary employee injuries aren’t recorded
You must record workplace incidents and injuries for all your workers, including part-time, seasonal, migrant, or temporary. Even if a temporary employee is not on your payroll (such as one from a staffing agency), you must still record their incidents if you have day-to-day supervision over them.
5. Case is misclassified
On the OSHA 300 form, employers must check a box to classify a case as a death, days away from work, job transfer or restriction, or other recordable. Many employers check multiple boxes if relevant, but OSHA requires that only one box is checked. When there is overlap, select the box that reflects the most serious outcome.
6. Misunderstanding what qualifies as a recordable case
If an injured employee can still perform useful work, do you need to record their incident? Yes! If the injury precludes the employee from performing one or more routine functions of their job (something they do at least once a week), it is a recordable case—even if they can still perform other work.
For instance, did you know that light duty can be a recordable restriction? It all depends on the physician’s specific instructions and limitations for the employee.
7. Days away from work are counted incorrectly
When counting days away from work, work restrictions, or job transfers, employers aren't sure how to count days away. In fact, OSHA requires you to include every calendar day, including vacation days, weekends, and holidays.
8. Incidents not recorded within 7 calendar days
Some employers get in the habit of updating their OSHA logs every month or even once a quarter, but this is just asking for an OSHA citation. Recordable injuries and illnesses must be recorded within seven calendar days of notification of the incident. In the event of a surprise inspection, this simple time gap could result in a fine.
9. Failure to keep logs for all covered establishments
OSHA requires separate 300 logs for each covered establishment, or location, within your organization. An establishment as defined by OSHA is “a single physical location where business is conducted or where services or industrial operations are performed.”
10. Incorrect certification of OSHA logs
Once OSHA logs are completed, OSHA requires that a company executive, corporate officer, or the highest-ranking official working at that location sign to certify the accuracy of the data. A safety manager or HR professional typically does not satisfy those requirements.
Want to make OSHA recordkeeping far easier for your clients (and prospects)? Check out OSHAlogs, simple OSHA reporting software that significantly reduces manual recordkeeping effort. It alerts you as the agent each time an incident occurs, opening a perfect follow-up conversation.
