The Occupational Safety and Health Administration issued a revised rule to improve the system employers use to track and record workplace injuries and illnesses. These were effective January 1, 2002.

OSHA's recordkeeping requirements, in place since 1971, were designed to:

• Help employers recognize workplace hazards and correct hazardous conditions by keeping track of work-related injuries and illnesses and their causes

• Produce better information about occupational injuries and illnesses while simplifying the overall recordkeeping system for employers

• Better protect employees' privacy

The rule gives employees more flexibility in using computers and technology to meet recordkeeping requirements.

Written in plain language using a question and answer format, the regulation for the first time uses checklists and flowcharts to provide easier interpretations of recordkeeping requirements. The revised rule includes a provision for recording needlestick and sharps injuries that is consistent with recently-passed legislation requiring OSHA to revise its bloodborne pathogens standard to address such injuries. This provision is expected to result in a significant increase in recordable cases annually.

The final rule affects approximately 1.3 million establishments. On January 23, 2002, the Public Employee Safety and Health Administration published Part 801 which is New York State’s version of the Recordkeeping rule.

"After three decades of what many employers considered complicated recordkeeping requirements with cumbersome forms and limited technological assistance, OSHA is revising this rule to address some of these concerns. This rulemaking completes a larger agency effort to revise, update, and simplify requirements that many considered too lengthy and complex," said OSHA Administrator Charles N. Jeffress. "The new rule combines previous regulatory requirements and interpretations into one clear and precise document that will aid an employer's ability to increase workplace safety."

The recordkeeping rule also conforms with OSHA's ergonomics standard published in November 2003. It simplifies the manner in which employers record musculoskeletal disorders (MSDs), replacing a cumbersome system in which MSDs were recorded using criteria different from those for other injuries or illnesses. The revised forms have a separate column for recording MSDs, which will improve the compilation of national data on these disorders.

One of the least understood concepts of recordkeeping has been restricted work. The new rule clarifies the definition of restricted work or light duty and makes it easier to record those cases. Work-related injuries are also better defined to ensure the recording only of appropriate cases while excluding cases clearly unrelated to work.

The revised rule also promotes improved employee awareness and involvement in the recordkeeping process, providing workers and their representatives access to the information on recordkeeping forms and increasing awareness of potential hazards in the workplace. Privacy concerns of employees have also been addressed. The former rule had no privacy protections covering the log used to record work-related injuries and illnesses.

OSHA's recordkeeping requirements provide the source data for the Bureau of Labor Statistics (BLS) Occupational Injury and Illness Survey, the primary source of statistical information concerning workplace injuries and illnesses. BLS collects the data and publishes the statistics, while OSHA interprets and enforces the regulation.

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