OSHA Recordkeeping and Reporting: A Quick Review

OSHA recordkeeping and reporting requirements appear straightforward, but the devil is in the details.

Now Returning to Our Regularly Scheduled Program…

John in Official 'Fish Red', White and Blue

John is NOT wearing an Official Fish Uniform

Happy July Everyone!

I hope you are all enjoying your summer.  We at Fish Window Cleaning – Los Angeles South Bay are having a terrific one!

Simply put: The weather gets hot and people want clean windows!

Summer is our busiest time of year and our expanding window cleaning team is doing a great job meeting our customers’ needs.

The Window Cleaning business is booming and we are set to break our production record this summer as we clean commercial and residential windows through Labor Day.

A new record is a good reason to miss a few posts, don’t you think?  Go Fish!   

Personal Best

Our Best Summer So Far!

Our busy schedule has consumed my time but I’m now back to my regular schedule and I will continue to write & post every week.

I hope you’ve enjoyed this year’s articles so far.  I’ve just completed my Q3/Q4 Blog Post calendar, there are so many exciting topics to cover!

Please let me know if there are any topics you’d like to see, I’m happy to fit them in the schedule.

Anyway, I’m back at it.

Thank you for your feedback & support!

This Week’s Topic: OSHA Regulations

The #1 topic that I post on “A Clear View Through Clean Windows” is OSHA related.  These posts are generally targeted for those running a window cleaning business or something similar, the #2 topic is safety (something we all relate to).  We must give the public what they want!

Look for more articles on both topics!

Tom Patton - Risk Manager, BBSI

Tom Patton, BBSI

So, let’s get back to it… Here’s a quick reminder of the main OSHA recordkeeping and reporting requirements.

Please let me know if you find this information useful.

Safety is a serious topic and our company, Fish Window Cleaning, adheres to all OSHA regulations.

Today’s OSHA related information is provided by our company’s Risk Manager, Tom Patton.

Tom works for Barrett Business Services, Inc. (BBSI), our Professional Employer Organization (PEO), and helps make sure we receive up-to-date  safety techniques and information, and he monitors us regularly to make sure we follow our safety training program and conform to all OSHA safety regulations.

OSHA Recordkeeping and Reporting Requirements

The OSHA recordkeeping standard requires you to keep records of occupational deaths, injuries and illnesses, and make reports to OSHA and the Bureau of Labor Statistics (BLS). Small employers (10 or fewer workers) and employers in certain retail, service, finance, real estate or insurance industries are not required to keep these records. However, they must report any occupational fatalities or catastrophes that occur in their workplaces to OSHA, and they must participate in government surveys if they are asked to do so.

OSHA Forms

Cal-OSHA Website

Cal-OSHA Website

The regulations require you to complete three forms:

  • OSHA 300 Log of Work-Related Injuries and Illnesses,
  • OSHA 301 Injury and Illness Incident Report
  • OSHA 300A Summary of Work-Related Injuries and Illnesses (annual)

The 300 log must include injuries and illnesses to employees on your payroll as well as to other employees you supervise on a day-to-day basis, such as temporary workers or contractor employees who are subject to daily supervision by your organization.

Work-Related Injuries

Section 1904.5(a) states that “[the employer] must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment….”

Note that the work event or exposure need only be one of the discernible causes of the injury or illness. It doesn’t have to be the sole or predominant cause.

Reporting Work-Related Injuries

Reporting Work-Related Injuries

Section 1904.5(b)(3) says that if it is not obvious whether the precipitating event or exposure occurred in the work environment or elsewhere, you “must evaluate the employee’s work duties and environment to decide whether or not one or more events or exposures in the work environment caused or contributed to the resulting condition or significantly aggravated a pre-existing condition.”

If you decide the case is not work-related, and OSHA subsequently issues a citation for failure to record, OSHA—not you—would have the burden of proving that the injury or illness was work-related.

Recording New Cases

Only new cases are record-able. Work-related injuries and illnesses are considered to be new cases when the employee has never reported similar signs or symptoms before, or when the employee has recovered completely from a previous injury or illness and workplace events or exposures have caused the signs or symptoms to reappear.

Recording Restricted Work

When an injury or illness involves restricted work or job transfer but does not involve death or days away from work, you must record the injury or illness on the OSHA 300 Log by placing a check mark in the space for job transfer or restriction and an entry of the number of restricted or transferred days in the restricted workdays column.

However, you don’t have to record a case where, for example, the employee only experiences minor musculoskeletal discomfort and the doctor says he’s fit to work, but assigns a work restriction to that employee for the purpose of preventing a more serious condition from developing.

Getting Back to Work is Very Important

Getting Back to Work is Very Important

An employee’s work is considered “restricted” when, as a result of a work-related injury or illness:

  • You keep the employee from performing one or more of the routine functions of his or her job (job functions that the employee regularly performs at least once per week), or from working the full workday that he or she would otherwise have been scheduled to work; or
  • A physician or other licensed health care professional recommends that the employee not perform one or more of the routine functions of his or her job, or not work the full workday that he or she would otherwise have been scheduled to worked.

For recordkeeping purposes, an employee’s routine functions are those work activities the employee regularly performs at least once per week.

A recommended work restriction is recordable only if it affects one or more of the employee’s routine job functions. To determine whether this is the case, you must evaluate the restriction in light of the routine functions of the injured or ill employee’s job.

A partial day of work is recorded as a day of job transfer or restriction for recordkeeping purposes, except for the day on which the injury occurred or the illness began.

Count days of job transfer or restriction in the same way you count days away from work. The only difference is that, if you permanently assign the injured or ill employee to a job modified or permanently changed to eliminate the routine functions the employee was restricted from performing, you may stop the day count when the modification or change is permanent. You must count at least 1-day of restricted work or job transfer for such cases.

I hope you found this article “OSHA Recordkeeping and Reporting: Quick Review” helpful.

Remember: Complying with OSHA regulations is important and it’s the Law!

Be Safe Everyone!


About the Author

John Gran & Cynthia Julian

John and Cynthia

John Gran (@FishSouthBay) is an entrepreneur and former marketing and product development executive who has grown his successful Fish Window Cleaning franchise in the Los Angeles – South Bay area to become a leading professional in window cleaning services for business owners and home owners.

With his popular blog A Clear View Through Clean Windows, John shares his window cleaning expertise by addressing topics and answering questions that customers continually ask him during his day.  He also uses window cleaning pictures, inspirations and stories about his business to demonstrate the fundamentals for building a strong, healthy, thriving business.

John lives & works with his wife Cynthia in Redondo Beach, CA (she runs the business too!)

If you have a question or would like window cleaning services click Here or Call 310-973-3474 for a Free, on-site written estimate.

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