Small Business Owner Four Part Safety Program: Part #4 – Documentation

Documentation is an essential element of a safety program. Essential records, including those legally required for workers’ compensation, insurance audits, and government inspections, must be maintained as long as required by law and an actual need exists. Keeping records of your activities, such as policy statements, training sessions for management, workers’ safety and health meetings held, information distributed to workers, and medical arrangements made, is greatly encouraged.

Maintaining essential records also will aid in the demonstration of sound business management as supporting proof for credit applications, for showing “good faith” in reducing any proposed penalties from OSHA inspections, and for insurance audits. Additionally, documentation will enable the efficient review of current safety and health activities for better control of operations and to plan improvements.

Safety and Health Recordkeeping

Records of sales, costs, profits and losses are essential to all successful businesses. They enable the owner or manager to learn from experience and to make corrections for future operations. Records of accidents, and related injuries, illnesses and property losses, can serve the same purpose, if they are used the same way. The sole purpose of OSHA recordkeeping is to store factual information about certain accidents that have happened. When the facts have been determined, causes can often be identified, and control procedures can be instituted to prevent a similar occurrence from happening.

Injury/Illness Records

OSHA requires injury/illness recordkeeping that can provide you with one measure for evaluating the success of your safety and health activities. Success would mean a lack of, or a reduced number of, worker injuries or illnesses during the following calendar year. There are five important steps required by the OSHA recordkeeping system:

  1. Obtain a report on every injury requiring medical treatment (other than first aid).
  2. Record each injury on the OSHA Form No. 300 according to the instructions provided.
  3. Prepare a supplementary record of occupational injuries and illnesses for recordable cases either on OSHA Form No. 101 or on workers’ compensation reports giving the same information.
  4. Every year, prepare the annual summary (OSHA Form No. 300); post it no later than February 1, and keep it posted until March 1. (Next to the OSHA workplace poster is a good place to post it.)
  5. Retain these records for at least 5 years.

During the year, periodically review the records to see where injuries are occurring. Look for any patterns or repeat situations. These records can help you to identify those high risk areas where you should direct your immediate attention. You might consider expanding your own system to include all incidents, including those where no injury or illness resulted. Safety councils, insurance carriers, and others can assist you in instituting such a system. There are some limited exemptions for small business employers who employ l0 or fewer workers, as well as for businesses that have certain SIC codes. Regardless of the number of workers you have or the SIC classification; you may be selected by the Federal Bureau of Labor Statistics (BLS), or a related State agency, for inclusion in an annual sample survey. The specific agency will send you a letter, if you are selected.

Exposure Records and Others

The injury/illness records may not be the only records you will need to maintain. Certain OSHA standards that deal with toxic substances and hazardous exposures require records on the exposure of workers, physical examination reports, employment records, etc. As you work on identifying hazards, you will be able to determine whether these requirements apply to your situation on a case-by-case basis. It is mentioned here so that you will be aware of these records and that, if required, they should be used with your control procedures and with your self-inspection activity to analyze your exposures – they should not be considered merely as bookkeeping.

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