Is your Facility Partially Exempt from OSHA Injury and Illness Recordkeeping?
All companies covered by the Occupational Safety and Health Act are covered by Part 1904 Recording and Reporting Occupational Injuries and Illnesses. However, some partial exemptions for keeping OSHA injury and illness records may apply to your workplace, including size and particular low-hazard industries.
If your facility applies to either of the two exemptions below, your facility is not required to keep OSHA injury and illness records.
Size Partial Exemption
Suppose your company had ten or fewer employees at any time during the last calendar year. In that case, you do not need to keep OSHA injury and illness records unless OSHA or the Bureau of Labor Statistics (BLS) informs you in writing that you must keep records.
Example 1: Suppose you had eight people working at your facility, but you had to add five temporary employees during the holiday season. You had 13 employees at one point during the calendar year. Thirteen employees means you are not exempt because you passed the ten employees or less rule during the calendar year. You had more than ten employees and must keep injury and illness records.
Example 2: If you have two business locations, with each site with nine employees, you are not exempt because this rule applies to the number of employees in the entire company, not at each location. You have 18 employees in the company and must keep injury and illness records.
Bottom line: If you had ten employees or fewer total at any time in the last calendar year, your company is eligible for the partial exemption for size. This means you are exempt from keeping OSHA injury and illness records.
Low-Hazard Industries Partial Exemption
Suppose your business establishment is classified by the North American Industry Classification System (NAICS) codes in a specific industry group listed in 1904 Appendix A. In that case, you do not need to keep OSHA injury and illness records. However, if you are asked in writing by OSHA or BLS, you must keep records.
Some examples of low-hazard industries are full-service restaurants, dentist offices, florists, and clothing stores.
Not sure what your NAICS code is? You can contact an OSHA office or State Agency to help determine your NAICS code.
Bottom line: If your industry and NAICS code are on Appendix A, you are partially exempt from OSHA injury and illness recordkeeping.
No Exemptions Here
Regardless of partial exemptions for size or low hazards, all facilities must report all work-related fatalities within 8 hours to OSHA. In addition, all work-related inpatient hospitalizations, amputations, and losses of an eye must be reported within 24 hours.
Remember, you can report injuries to OSHA online or call the OSHA 24-hour hotline at 1-800-321-6742 (OSHA).
Not sure what injuries or illnesses need to be recorded or reported to OSHA? Contact us today.
This blog was written by Brandy Bossle, Triangle Safety Consulting LLC's Owner and Principal Consultant.
She offers audits, expertise, resources, and guidance to help small to medium-sized manufacturing facilities improve their safety program, including compliance with OSHA Requirements.
She is a Certified Safety Professional (CSP) under the Board of Certified Safety Professionals.
