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Best Practices for Maintaining OSHA Recordkeeping Compliance

The Occupational Safety and Health Administration, better known as OSHA, is an agency of the United States Department of Labor, and its mission is to “assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education, and assistance.” Its role is to ensure that every commercial entity provides each of its employees with a safe and secure work environment. OSHA is constantly observing how companies handle emergencies and situations where safety may be compromised. They require most companies to record issues and complaints and report them to OSHA offices.

According to OSHA, the importance of recordkeeping is a critical part of an employer’s safety and health efforts for a few reasons:

  • No organization is free or immune from the risks of employees being injured in the workplace. Tracking any work-related injuries can help your organization prevent them from happening in the future.
  • Maintaining injury and illness data help your organization achieve compliance, identify, and mitigate risks. This will help you identify and correct hazardous workplace conditions and will guide your organization in making safety plans, programs, and implementation.
  • Provide training for employees to raise awareness about injuries, illnesses, and hazards in the workplace to avoid accidents.

Know OSHA's Recordkeeping Requirements

OSHA has strict requirements when it comes to keeping accurate records. For example, if a company has more than 10 workers, it is required to maintain records of all serious injuries that are related to work. Any minor injuries that do not require a visit to the doctor aren’t mandatory for reporting. There are also certain industries that are lower risk and not required to maintain these records.

To remain in compliance with OSHA’s recordkeeping requirements, you must understand two important things. First, you need to know what the definition is of a recordable illness or injury. According to OSHA, recordable illnesses or injuries are:

  • Any work-related fatality.
  • Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
  • Any work-related injury or illness requiring medical treatment beyond first aid.
  • Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
  • There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.

Next, you must also understand what constitutes first aid. First aid is medically-related attention that is usually administered immediately after the injury occurs and at the location where it occurred such as cleaning, flushing, or soaking wounds on the surface of the skin, or using wound coverings or any non-rigid means of support, etc. It is any short-term or one-time treatment performed using minimal technology or training by the person who administered the first aid.

These two distinctions will determine whether an injury or illness must be reported according to OSHA standards. Injuries that do not require medical treatment beyond first aid are generally not considered as recordable, however you should refer to OSHA for a complete list. This type of information will help maintain a safe environment within the workplace and allow employers to provide the necessary equipment that will keep their employees safe.

Understand the Recordkeeping Process

Another consideration to achieve compliance is to understand your recordkeeping process. OSHA requires that three different forms be used to keep accurate records when it comes to reporting injuries and illnesses. They are forms 300, 300A, and 301. Each of these forms comes with specific instructions on how to complete them. Each form requires specific information that OSHA uses to help keep an accurate profile for every company.

Obtaining a copy of OSHA Recordkeeping Regulations (29 CFR 1904) will have all the information a company needs to fulfil all its obligations and remain in compliance with all of OSHA’s recordkeeping processes. It’s important to make sure that all these processes are thoroughly understood and followed to the letter.

OSHA now uses the ITA or Injury Tracking Application that allows employers to submit the information from their 300A forms. Any employer who is required to submit the information that pertains to work-related injuries must submit their forms in a timely fashion. Since the onset of the COVID-19 pandemic, certain guidelines have been put in place. At this time, the only document that must be submitted electronically is the OSHA 300A. This is the Summary of Work-Related Injuries and Illnesses. All other forms, primarily the 300 and 301 can be submitted manually.

Staying in Compliance

The ever-evolving OSHA provisions and associated deadlines make it harder for organizations to keep up and can be a major challenge for time and costs. Also, several states are enforcing these updates differently which makes it more complicated and time-consuming. To stay in compliance, employers, health care providers, and payors need to stay updated and well informed about the federal changes as well as the implementation of their state’s OSHA plan.

With the right solution, expert guidance, and collaboration within your stakeholders, your organization can successfully navigate and implement OSHA’s reporting and recordkeeping. Here’s where to start:

  1. Audit your existing OSHA plan or practices from time to time. Review the current implementation of your policies to know what needs to be done or change accordingly. You may also talk to an expert or a team of highly skilled professionals to guide you through an entire implementation. Xybion has a team of experts ready to support you.
  2. Keep your official policies up to date. Always update your organization’s documents and programs that need to be changed. Have an expert in OSHA recordkeeping review all your existing documents and programs to make sure that they are compliant. Xybion’s Emidence XD can record inspections, investigations, report findings, and create CAPAs (Corrective Action & Preventive Actions) as well as submit compliant incident documentation such as the 300A to OSHA.
  3. Collaboration with all stakeholders such as employers, payors, and providers. A software like Emidence XD can eliminate disconnected data siloes by integrating the exchange of data between different business functions – EHS, claims, finance, compliance, quality, operations, HR, and more.

Top 5 Best Practices for Maintaining OSHA Recordkeeping Compliance

Here are the top 5 best practices to help your organization on ways that can leverage and strengthen your approach towards achieving compliance in OSHA recordkeeping:

  1. Maintain and post the required records at the worksite. OSHA states that all OSHA-related records must be kept for a minimum of at least five years. From February to April every year, companies must post a document that lists all the recordable events (both injuries and illnesses) that were reported throughout the previous year. Copies of the records must also be provided to any current or former workers, or individuals who represent their interests.
  2. Display an OSHA information poster in a conspicuous place that is visible to all employees that include their rights and responsibilities in the workplace.
  3. Train managers, supervisors, and employees regularly to avoid accidents. Get the most out of your training using Emidence XD which provides training management that empowers organizations to provide training through online, instructor-led virtual courses, where an individual or a group can access desired topics through secure user access control, thus allowing stakeholders to learn at their own pace, with track and reporting.
  4. Be always inspection ready. The Occupational Safety and Health Administration regularly conducts workplace inspections across different states. Always make sure that you have a full audit trail that promotes data integrity, reduces staff training time and system support costs, and streamlines reporting activities thereby lowering the total cost of ownership.
  5. Keep and track all your illnesses and injury reports into place because it will also help your organization establish a better course of action for future incident prevention. Emidence XD with embedded Enterprise Content Management simplifies collaboration, creates content, and transmits and assures compliance across all parts of your business processes.

Technology is Transforming Employee Health and Safety

Remaining in compliance with OSHA standards is an important part of doing business. According to OSHA they have required businesses across the United States to submit workplace illness and injury reports digitally since July 2018 with noncompliance fees starting at over $10,000. Unfortunately, several organizations have yet to make the shift to managing their employee health and safety data digitally.

As technology becomes widespread in every industry, the Occupational Safety and Health Administration is evaluating how technology can help streamline EHS processes that provide operational and safety visibility and guide in record-keeping of data. According to Verdantix, an independent research firm, organizations are increasingly adopting EHS software for a wide range of uses. Verdantix stated that “Xybion has designed its platform with consideration of the complex and ever-evolving landscape of EHS regulatory compliance.” Today, the out-of-the-box digital solution takes the complexity out of meeting OSHA’s new reporting guidelines and helping organizations to successfully shift towards digital transformation. Emidence XD is a state-of-the-art, innovative solution to manage Workforce Health, Medical Care, Case, OSHA Reporting, Workers’ Comp, and Compliance Management. Emidence XD is revolutionizing the new paradigm of digital transformation by enabling organizations to create a safer workplace that helps reduce risks and costs while improving employee health and safety.

Thus, staying in compliance with OSHA’s guidelines and regulations is a game-changer for businesses to embrace digital transformation to modernize their key business processes. With the right EHS software, your organization can keep all incident reports in a single database making reporting on employee incidents easier, bringing new data insights, and providing more visibility across the business. At Xybion, we are committed to helping highly regulated companies on taking a holistic approach towards a more digital working environment while maintaining compliance. Adapting the right Workplace Health and Safety platform will help you move forward in this new digital era of employee health and safety.

With so many EHS solutions available, how can you effectively choose the right platform for your company? Let these considerations guide you through the process:

  • Look for a unified EHS Solution that is configurable and highly scalable. It should facilitate cross-functional communication and optimize business processes.
  • EHS solutions should be people-centric with end-to-end employee safety management.
  • EHS should provide predictive compliance risk management.
  • Ensure the solution offers Enterprise Content Management that improves real-time collaboration through seamlessly connecting medical care and insurance claims.

The industry is shifting to a centralized EHS platform to improve workplace safety, increase efficiency, and reduce employee incidents.


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