The basics of OSHA/PERRP reporting

Under the Occupational Safety & Health Administration’s (OSHA) record keeping regulation, certain covered private employers — entities run by private individuals or groups — are required to prepare and maintain records of serious occupational injuries and illnesses using the OSHA 300 Log. In Ohio, public employers — cities, counties, public schools, villages, etc. — are also required by the Ohio Public Employer Risk Reduction Program (PERRP) to maintain the same records on the PERRP 300P log.

“The information is intended to help employers evaluate the safety of their workplace as well as help implement protection for their workers in order to reduce and/or eliminate hazards,” says Cassy Taylor, senior risk services analyst at CompManagement.

Smart Business spoke with Taylor about some of the fundamentals of maintaining these records and the approaching deadlines for posting.

Who is responsible for keeping injury and illness records?

Private employers with 10 or more employees at any point during the year, with the exception of certain low-risk industries, are required to keep an OSHA 300 log. The list of certain low-risk industries may be viewed on OSHA’s website. Private employers with 10 or fewer employees for the entire year are required to keep records if directed to do so by OSHA. All public employers are required to keep a PERRP 300P log. There are no exemptions for public employers.

What is a recordable injury or illness?

Employers must record each fatality, injury or illness that is work-related; if it is a new case or meets one or more of the criteria contained in the OSHA/PERRP record keeping instructions that include death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness or diagnosis of a significant injury/illness by a physician or other practicing licensed health care professional.

What cases are considered work-related?

An event or exposure in the work environment that either caused or contributed to the resulting condition, or an event or exposure in the work environment significantly aggravated by a pre-existing injury or illness.

Are there any exceptions?

Yes, there are a few exceptions to the record keeping rule that include being present as a member of the general public; voluntary participation in wellness program, medical, fitness or recreational activity; eating, drinking or preparing food or drink for personal consumption; symptoms arising in work environment that are solely due to a non-work-related event or exposure; personal tasks outside assigned working hours; personal grooming, self- medication for non-work-related condition, or intentionally self-inflicted; a motor vehicle accident in a parking lot/access road during a commute; common cold or flu; and mental illness, unless the employee voluntarily provides a medical opinion from a physician or licensed health care professional having appropriate qualifications and experience that affirms work-relatedness.

How long do records need to be kept on file and is there a deadline to post?

OSHA 300 and PERRP 300P logs cover one calendar year and must be kept on file for five years. The information on the OSHA 300 and PERRP 300P logs must be transferred to the OSHA 300A and PERRP 300AP summary forms for posting. Private employers must post the 300A for all employees to see from Feb. 1 to April 30 of each year; there is no need to submit the log to OSHA unless asked to do so. Public employers must post the 300P for all employees to see from Feb. 1 to April 30 of each year as well as submit the report to the Ohio Bureau of Workers’ Compensation by Feb. 1.

Are all recordable injuries or illnesses also workers’ compensation claims?

No. For example, if the injured party only received treatment from an in-house physician, a workers’ compensation claim may not need to be filed. If the treatment was beyond first aid, it must be recorded on the 300 or 300P log.

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