This article discusses some of the salient and often vexing questions that employers must address with their OSHA recordkeeping compliance. It also discusses proposed changes to the Federal reporting requirements to notify OSHA in the event of accident resulting in employee injury, from the present rule requiring notice to OSHA within eight hours of a fatality or catastrophe (three or more employees hospitalized in one incident) to a much lower “threshold” of requiring a report to OSHA of all in-patient hospitalizations within eight hours and any amputation within twenty four hours. If this becomes effective, it will trigger many more OSHA inspections. Some states, which are referenced, already have these lower thresholds. The article highlights many of the more common questions encountered in deciding whether an injury or illness is recordable on the OSHA 300 Log. The article was driven by many recent citations we have seen in this area.

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