RECORDKEEPING & REPORTING: Overview of Proposed Changes to Injury Reporting Rules

Date First Published on SafetySmart Compliance: February 21st, 2012
Topics: Recordkeeping |

Retrieved by: Occupational Safety & Health Administration

One of the obligations of the OSHA Recordkeeping & Reporting Occupational Injuries and Illnesses standard is to report workplace injuries to OSHA within certain deadlines after they occur (Section 1904.39). On June 22, 2011, OSHA proposed changes to broaden injury reporting requirements. Here’s a look at the changes contained in the OSHA proposal.

Current Rule

Employers are required to report verbally, i.e., by phone or in-person by showing up at the nearest OSHA Area Office, within 8 hours after the occurrence of (or first learning about) an incident that results in a workplace fatality or the hospitalization of 3 or more employees.

Proposed Changes

The gist of the OSHA proposal is to make more incidents high-priority items warranting immediate reporting. The obligation to report fatalities within 8 hours wouldn’t change. But 2 things would:

Change 1: First, you’d have to report to OSHA within 8 hours incidents resulting in the in-patient hospitalization of one or more (not 3 or more) employees.

Change 2: The proposal would also require you to report a work-related amputation to OSHA within 24 hours.

What to Do in Response to Changes

When and if the proposal is finalized and takes effect, you’ll need to revise your OSHA reporting procedures to comply with the new requirements. Fatality reporting won’t change. But what you will need to do is:

Revise your hospitalization reporting procedures: The key to compliance will be recognizing that any hospitalization will have to be reported if it’s in-patient. You need to understand that in-patient means a formal admission, as opposed to an ER visit or outpatient procedure where the employee leaves right afterward without spending the night.

Require reporting of amputations: The second thing you’ll need to do is add an obligation to report to OSHA workplace amputations within 24 hours after they occur. You need to recognize that amputation means the traumatic loss of a limb or other external body part, including a fingertip.  For an injury to be classified as an amputation that’s reportable to OSHA, bone must be lost. So, loss of an eye is not considered an amputation. But amputation would include amputations that occur at the workplace or in a hospital as a result of a work-related event.

Click here for a Model OSHA Reporting Policy that incorporates language necessary to comply with the new reporting requirements.