Safety & Health Recordkeeping

No operation can be successful without adequate safety and health recordkeeping, which enables you to learn from past experience and make corrections for future operations. Records of accidents, work-related injuries, illnesses and property losses serve as a valuable purpose.

Under Cal/OSHA recordkeeping requirements, all information on accidents is gathered and stored. Upon review, causes can be identified and control procedures instituted to prevent the illness or injury from recurring. Keep in mind that any inspection of your workplace may require you to demonstrate the effectiveness of your program.

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Injury & Illness Records

Injury and illness recordkeeping requirements under Cal/OSHA require a minimum amount of paperwork.

These records give you one measure for evaluating the success of your safety and health activities: success would generally mean a reduction or elimination of employee injuries or illnesses during a calendar year.

Five important steps are required by the Cal/OSHA recordkeeping system:

  1. Each employer (unless exempt by size or industry) must record each fatality, injury or illness that is work-related, is a new case, or meets one or more of the general recording criteria specified in Title 8, Section 14300.
  2. Record each injury or illness on the Cal/OSHA Log of Occupational Work Related Injuries and Illnesses (Form 300) according to its instructions.
  3. Prepare an Injury and Illness Incident Report (Form 301), or equivalent.
  4. Annually review and certify the Cal/OSHA Form 300 and post the Summary of Work-Related Injuries and Illnesses (Form 300A) no later than February 1 and keep it posted where employees can see it until April 30.
  5. Maintain the last five years of these records in your files.NOTE: Additional information on recordkeeping can be found on the Internet at: www.californiaosha.info or www.dir.ca.gov/DOSH

During the year, regularly review these records to see where your injuries and illnesses are occurring. Look for any patterns or repeat situations. These records can help you identify hazardous areas in your workplace and pinpoint where immediate corrective action is needed.

Since the basic Cal/OSHA records are for reportable injuries and illnesses only, you might expand your system to include all incidents relating to workplace safety and health, even those where no injury or illness resulted. Such information can assist you in pinpointing unsafe acts, conditions or procedures.

Exposure Records

Injury and illness records may not be the only records you need to maintain. Cal/ OSHA standards concerning toxic substances and hazardous exposures require records of employee exposure to these substances and sources, physical examination reports, employment records, and other information.

Employers using any regulated carcinogens have additional reporting and recordkeeping requirements. See Title 8 of the California Code of Regulations for details.

Documentation of Your Activities

Essential records, including those legally required for workers’ compensation, insurance audits and government inspections must be maintained for as long as required.

For most employers, Cal/OSHA standards also require that you keep records of steps taken to establish and maintain your Injury and Illness Prevention Program. They must include:

  1. Records of scheduled and periodic inspections as required by the standard to identify unsafe conditions and work practices. The documentation must include the name of the person(s) conducting the inspection, the unsafe conditions and work practices identified, and the action taken to correct the unsafe conditions and work practices. The records are to be maintained for at least one year. However, employers with fewer than 10 employees may elect to maintain the inspection records only until the hazard is corrected.
  2. Documentation of safety and health training required by standards for each employee. The documentation must specifically include employee name or other identifier, training dates, type(s) of training and the name of the training provider. These records must also be kept for at least one year, except that training records of employees who have worked for less than one year for the employer need not be retained beyond the term of employment if they are provided to the employee upon termination of employment.

Also, employers with fewer than 10 employees can substantially comply with the documentation provision by maintaining a log of instructions provided to the employee with respect to the hazards unique to the employees’ job assignment when first hired or assigned new duties. Some relief from documentation is available for employers with fewer than 20 employees who are working in industries that are on the Department of Industrial Relations (DIR’s) designated list of low-hazard industries, and for employers with fewer than 20 employees who are not on DlR’s list of high-hazard industries and who have a Workers’ Compensation Experience Modification Rate of 1.1 or less.

For these industries, written documentation of the Injury and Illness Prevention Program may be limited to:

  1. Written documentation of the identity of the person or persons with authority and responsibility for implementing the program;
  2. Written documentation of scheduled periodic inspections to identify unsafe conditions and work practices; and
  3. Written documentation of training and instruction.

Keeping such records fulfills your responsibilities under General Industry Safety Order 3203. It also affords an efficient means to review your current safety and health activities for better control of your operations and to plan future improvements.

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