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Solid Recordkeeping Advice Can Keep You Off OSHA's Radar

Tue Jan 8, 2008 1:02pm EST
NEENAH, Wis.--(Business Wire)--Every year, the U.S. Occupational Safety and Health Administration
sends letters to approximately 80,000 employers across the country
requesting their injury and illness data from the previous year. This
is reported in what's known in the industry as the 300A Summary of
Work-Related Injuries and Illnesses. From this data, OSHA picks 14,000
workplaces with the highest incident rates. Not only are these
workplaces listed on OSHA's website, but from the 14,000 workplaces
listed, 4,500 are then targeted for wall-to-wall inspections.

   "As we begin a new year," notes Julie Nussbaum, a compliance
subject matter expert with J. J. Keller & Associates, "I cannot
overestimate the importance of accurate recordkeeping. Too many
employers record injuries that don't need to be recorded ... skewing
their incident rate and making their safety performance appear
questionable."

   Nussbaum says it's critical for employers to become familiar with
OSHA requirements and document only those cases that meet OSHA's
recordability criteria. She offers the following three pieces of
advice for accurate OSHA 300 recordkeeping.

   #1: Learn about OSHA's injury and illness recordkeeping exemptions

   "All employers under OSHA jurisdiction are covered by the 1904
recordkeeping regulations," says Nussbaum, "however, there are some
exceptions. Certain industries such as retail, service, finance,
insurance and real estate have low incident rates (at or below 75% of
the national average) and do not have to keep injury and illness
records. The same is true if a company had ten or fewer employees at
all times the previous year." Nussbaum cautions that these exceptions
fall under federal requirements and suggests employers check if there
are any additional state requirements.

   #2: Brush up on how to record OSHA recordable days

   According to Nussbaum, employers need to count all calendar days
the employee is off work or on restricted duty/job transfer. She
states, "You need to count all calendar days that employees were
unable to perform their regular jobs, regardless of whether they were
scheduled to work. This includes weekends, holidays and vacation
days."

   "You don't," she continues, "need to count the first day. Start
counting on the day after injury occurred or illness began. And keep
in mind OSHA's provision that allows you to cap the count at 180 days
total for any one case."

   #3: Know the difference between recordable and non-recordable
cases

   Nussbaum says three key elements must be met in order for an
injury or illness to be recordable.

   First, it must be work-related. This means that an event or
exposure in the workplace causes or contributes to an injury or
aggravates a pre-existing condition.

   Second, it must be a new case, which means the employee hasn't had
a recordable injury or illness of the same type to the same part of
the body. Nussbaum explains that it is also considered a new case if
the employee has completely recovered from a previous recordable
injury/illness (that is, all signs and symptoms have disappeared) and
a workplace event causes symptoms to reappear.

   Finally, in order for an injury or illness to be recordable, it
must meet OSHA's general or specific recording criteria. "OSHA
currently lists seven general and five specific types of injuries and
illnesses that make a case recordable," says Nussbaum. "All others are
not recordable."

   J. J. Keller will provide more detailed information on this topic
in a webcast titled The Workplace Injury or Illness: What Makes it
OSHA Recordable presented on January 17th at 11 a.m. (CST). To
register, simply go to www.jjkeller.com/osharec4.

   About J. J. Keller

   J. J. Keller & Associates, Inc. was established in 1953 and has
become the nation's most respected name in risk and regulatory
management. The company employs nearly 1,200 associates and serves
over 300,000 customers including more than 90% of the Fortune(R)
1,000. Keller's diverse product line includes publications,
consulting, online services, and outsourced services. For more
information, visit www.jjkeller.com.

   To download text of this release electronically, go to
www.jjkeller.com/jjkpressroom.

J. J. Keller & Associates, Inc.
Marketing Communications
Jean Bilitz
1-800-843-3174, ext. 7304
jbilitz@jjkeller.com
or
Janal Emmer
1-800-843-3174, ext. 2720
jemmer@jjkeller.com

Copyright Business Wire 2008



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