CompManagement Health Systems Client Bulletin

December 17, 2014

OSHA/PERRP recordkeeping reports
Employers are required to post by February 1, 2015

We are getting close to that time of year when employers must organize and finalize their records of work-related injuries and illnesses. The Occupational Safety & Health Administration (OSHA) and the Public Employers Risk Reduction Program (PERRP) mandate that employers must post a summary of work-related injuries from February 1 through April 30 for injuries that occurred in the previous year. The summary (OSHA 300A or PERRP 300 AP) must be in a visible location so that employees are aware of the injuries and illnesses occurring in their workplace. A company executive is required to certify the summary by signing it. Recording an injury or illness under the OSHA system does not necessarily imply that either management or the employee was at fault, that a violation of an OSHA standard has occurred or that the injury or illness is compensable under workers' compensation or other systems.

The three injury and illness recording forms that should be maintained by employers are:

  • OSHA 300/PERRP 300P – Log of Work-Related Injuries and Illnesses
  • OSHA 301/PERRP 301P – Injury and Illness Incident Report
  • OSHA 300A/PERRP 300AP – Summary of Work-Related Injuries and Illnesses

One of the most frequently asked questions is “what is recordable?” The answer is employers must record any work-related injury or illness resulting in one of the following:

  • Death
  • Days away from work
  • Restricted work or transfer to another job
  • Medical treatment beyond first aid
  • Loss of consciousness
  • Diagnosis of a significant injury/illness by a physician or other licensed healthcare professional

Another key consideration is whether or not the injury or illness is work-related. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the workplace, which includes the establishment and other locations where one or more employees are working or are present as a condition of their employment.

The decision-making process consists of four steps. If the answer is yes to all of the questions below, the employer is to record the injury or illness.

  • Did the employee experience an injury or illness?
  • Is the injury or illness work-related?
  • Is the injury or illness a new case?
  • Does the injury or illness meet the general recording criteria or the application to specific cases?

Employers are required to keep a log for each establishment or worksite. If you have more than one establishment, keep a separate log and summary for each physical location that is expected to be in operation for one year or longer.

If you have questions, please contact your CHS Account Executive directly or call our customer service team at 888-247-7799.

Source: JJKeller Online which provides safety training resources for subscribers.

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