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RECORDKEEPING

 


Introduction

What's so important about recordkeeping?

Who is covered by MIOSHA's recordkeeping rule?

Brief Recordkeeping Questions and Answers.

How can I get more information on recordkeeping?



Introduction

Employers have a convenient system for tracking workplace injuries and illnesses. Michigan Occupational Safety and Health Administration’s (MIOSHA) recordkeeping log is easy to understand and to use.  Written in plain language using a question and answer format, the recordkeeping standard answers questions about recording occupational injuries and illnesses and explains how to classify particular cases.  Flowcharts and checklists make it easy to follow the recordkeeping requirements.


What's so important about recordkeeping?

How can we help employers reduce fatalities, injuries and illnesses on the job?  That is the fundamental question facing the MIOSHA program.  Our primary mission is to help ensure that every Michigan worker goes home healthy and whole every day.
Improving Michigan work environments requires daily diligence and ongoing commitment by employers in the face of competing priorities for time, energy and resources.  MIOSHA is committed to helping employers find the most effective and efficient ways to reduce injuries, illnesses, and deaths in the workplace.
One critical component to an employer's total safety and health effort is accurate recordkeeping. Here's why:

  • Conscientious and detailed records can provide employers with a clear picture of their work environment, and can help prevent work-related injuries and illnesses in the future.
  • Injury and illness data can help identify problem areas.  The more you know, the better you can identify and correct hazardous workplace conditions.
  • Employers can better administer company safety and health programs with accurate records.
  • As employee awareness about injuries, illnesses, and hazards in the workplace increases, workers are more likely to follow safe work practices and report workplace hazards.

Proper recordkeeping also helps MIOSHA identify high-hazard industries and worksites, and helps determine where our consultative and program resources should be directed.  Accurate records give direction to our prevention efforts and voluntary compliance activities.


Who is covered by MIOSHA's recordkeeping rule?

Employers with 11 or more employees are covered by MIOSHA's recordkeeping requirements. Covered employers must prepare and maintain records of work-related injuries and illnesses. You can review Part 11. Recording and Reporting of Occupational Injuries and Illnesses to see exactly which cases to record.

If you had 10 or fewer employees during all of the last calendar year or your business is classified in a partially exempt industry (see Appendix A of Part 11), you do not have to keep injury and illness records unless MIOSHA, Bureau of Labor Statistics (BLS), or the United States Department of Labor’s Occupational Safety and Health Administration (OSHA), informs you, in writing, that you must keep records.

These exemptions apply to recordkeeping only and do not excuse any employer from other MIOSHA requirements or from compliance with all applicable MIOSHA safety and health standards.

MIOSHA also notifies selected establishments each year to report data requested by OSHA, as well BLS.  If employers receive a BLS Survey or an OSHA Data Collection form, they must promptly complete the form and submit via mail or electronically to MIOSHA within 30 days.

MIOSHA recordkeeping rules have been in effect since the Michigan legislature created the modern MIOSHA program in 1975.  MIOSHA revised the recordkeeping standard in 2002 in accordance with federal OSHA recordkeeping revisions to provide clearer regulatory requirements which simplify the overall recordkeeping system for employers and employees.  The revised MIOSHA administrative rule Part 11. Recording and Reporting of Occupational Injuries and Illnesses went into effect January 1, 2002.


Brief Recordkeeping Questions & Answers

What is the basic recording requirement?
How do I determine if a case is work related?
How do I separate first aid from medical treatment cases?
What are the three required forms?
Which of the forms am I required to post?
Can I use the Workers' Compensation Form 100?
How do I record a work-related injury or illness that results in days away from work?
If an employee is injured in the afternoon, do I have to record a day away from work?
How do I record a case that results in restricted work or job transfer?
Does the standard protect employee privacy?
Do I need to record needlestick injuries?
Do I need to record musculoskeletal injuries?
How do I record hearing loss cases?
What are the new requirements for employee involvement?
How do I decide whether an injury or illness is work-related if the employee is on travel status at the time the injury or illness occurs?
Are company parking lots considered part of the employer's work premises?
Are motor vehicle accidents recordable?
What about employer-controlled recreational facilities?
What if our company has multiple facilities?
Who certifies the MIOSHA Form 300A?
Is it true all fatalities must be reported within eight hours to MIOSHA?


Q. What is the basic recording requirement?

A. Each employer is required to keep records of work-related fatalities, injuries and illnesses that meet one or more of the general recording criteria, including:

  • Death,
  • Days away from work,
  • Restricted work,
  • Transfer to another job,
  • Medical treatment beyond first aid,
  • Loss of consciousness, or
  • A significant injury/illness diagnosed by a physician or other licensed health care professional.

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Q. How do I determine if a case is work related?

A. A case is considered work-related if an event or exposure in the work environment either caused or contributed to the resulting condition.

A case is considered work-related if an event or exposure in the work environment significantly aggravated a pre-existing injury or illness. (Significant aggravation is defined in Rule 1110, 1110b(1) & (2).

Symptoms arising in the work environment that are solely due to a non-work-related event or exposure are not work related.

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Q. How do I separate first aid from medical treatment cases?

A. Medical treatment means the management and care of a patient to combat disease or disorder. It includes treatment of injuries administered by physicians, registered professional personnel, or lay persons (i.e., non-medical personnel).

Medical treatment does not include first aid treatment (one-time treatment and subsequent observation of minor scratches, cuts, burns, splinters, and so forth, which do not ordinarily require medical care) even though provided by a physician or registered professional personnel.

First Aid Examples

  • Using nonprescription medications at nonprescription strength.
  • Administering tetanus or diphtheria immunizations.
  • Bandaging minor cuts.
  • Using finger guards.
  • Using non-rigid means of support such as elastic bandages, wraps, non-rigid back belts, etc.
  • Using irrigation or a cotton swab to remove foreign bodies from the eye.
  • Cleaning, flushing or soaking wounds on the surface of the skin.

First aid is defined by a complete list of treatments in the standard Rule 1112d(3)(a)-(n). All treatment not on this list is medical treatment.

Medical Treatment Examples

  • Using prescription medications or non-prescription drugs at prescription strength.
  • Using wound closing devices such as surgical glue, sutures, staples, stitches.
  • Using any devices with rigid stays or other systems designed to immobilize parts of the body.

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Q. What are the three required forms?

A. Following are the three MIOSHA Recordkeeping forms:

  • Use the new MIOSHA Form 300 Log of Work-Related Injuries and Illnesses to list injuries and illnesses and track days away from work, days restricted or job transfer and cases resulting in medical treatment.  This form can be printed on legal-sized paper.
  • Use the MIOSHA Form 301 Injury and Illness Incident Report to record supplementary information about recordable cases.  This form includes data about how the injury or illness occurred.
  • Use the MIOSHA Form 300A Summary for Work-Related Injuries and Illnesses to show totals for the year in each category along with annual average number of employees and total hours worked.  This form provides additional data to make it easier for employers to calculate incidence rates.

Employers must enter each recordable injury and illness on the MIOSHA Forms 300 and 301 within seven calendar days of receiving the information that an injury or illness has occurred.
Maximum flexibility has been provided so employers can keep all the information on computers, at a central location, or on alternative forms, as long as the information is compatible and the data can be produced when needed, and displayed annually at separate establishments per 1132 (2)(E).

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Q. Which of the forms am I required to post?

A. Employers must post only the MIOSHA Form 300A Summary of the previous calendar year from February 1 to April 30. Companies with no injuries or illnesses in the previous calendar year must post the form with zeros on the total line.

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Q. Can I use the Workers' Compensation Form 100?

A. The Bureau of Workers' and Unemployment Compensation BWC-100 Form, First Report of Injury, is used for employers' basic report of compensable injuries and illnesses.  The Form 100 can be used in lieu of the MIOSHA Form 301 Injury and Illness Incident Report, by completing questions 1-9, 27-28, 33-45 and 54-57.  Employers must use the Form 100 that was revised April 2002, to qualify as a substitute for the MIOSHA 301.

The Form 100 can be downloaded, filled in, and the completed form can then be printed. Users can also save the file to their computer..

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Q. How do I record a work-related injury or illness that results in days away from work?

A. When an injury or illness involves one or more days away from work, you must record the injury or illness on the MIOSHA Form 300 with a check mark in the space for cases involving days away ("H" column) and an entry of the number of calendar days away from work in the number of days ("K" column).  You must also check the appropriate entry (1-6) in the "M" column.

If the employee is out for an extended period of time, you must enter an estimate of the days that the employee will be away and update the day count when the actual number of days is known.

The standard relies on calendar days, not workdays.  Count calendar days away from work, including holidays and weekends, instead of work days.  Do not count the day of the injury or illness, or the day the employee returns to work.  Employers may "cap" the total days posted at 180 calendar days.  This total would include days away, day of transfer or job restriction or the combination of the two.

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Q. If an employee is injured in the afternoon, do I have to record a day away from work?

A. No. A special point to remember when recording cases, is that the day of the injury or illness is not counted as a day away. Examples:

  • If an employee is injured on Monday and is absent on Tuesday, Wednesday, and Thursday, three days away should be recorded, not four.
  • If an employee is injured during the day and doesn't return the rest of the day, but begins work again the next morning, the case (if treated with medical treatment) would be logged in the "Remained at Work" category, without a day away.

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Q. How do I record a case that results in restricted work or job transfer?

A. 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 MIOSHA Form 300 by placing a check mark in the space ("I" column) for job transfer or restriction and an entry of the number of restricted or job transferred days in the "L" column.  You must also check the appropriate entry (1-6) in the "M" column.

Employers are required to record cases as restricted work cases when the injured or ill employee only works partial days or is restricted from performing any of their "routine job functions."

If an employer makes a permanent job transfer, stop counting the days of restricted work/job transfer and enter the total number of days restricted or job transfer on the log. (This must be at least one day.)

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Q. Does the standard protect employee privacy?

A. Employers are required to protect employee privacy by withholding an individual's name on the MIOSHA Form 300 for certain types of sensitive injuries/illnesses (e.g., sexual assaults, HIV infections, mental illnesses, contaminated needlesticks, etc.)  If the employer has a privacy case, they must keep a separate, confidential list of the case numbers and employee names.

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Q. Do I need to record needlestick injuries?

A. If employers fall under the recordkeeping requirements*, they are required to record all needlesticks and cuts from sharp objects contaminated with another person's blood or other potentially infectious material.

Employers are required to establish and maintain a Sharps Injury Log under the MIOSHA Bloodborne Infectious Diseases Standard for recording of percutaneous injuries from sharps. At a minimum, the log must include: the type and brand of device involved, the work unit or work area where the incident occurred, and how it happened. The information must protect the confidentiality of the employee.

The MIOSHA Form 300 can be used to meet the requirements of the sharps log, provided all of the above information is included. The record must be maintained in such a way that sharps injuries can be segregated from other types of work-related injuries and illnesses.

*Refer to Part 11 Recording and Reporting Occupational Injuries and Illnesses Appendix A - Partially Exempt Industries to determine which facilities are exempt from keeping the sharps injury log.

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Q. Do I need to record musculoskeletal injuries?

A. Musculoskeletal disorders (MSDs) are treated like all other injuries or illnesses. They must be recorded if they result in days away, restricted work, transfer to another job, or medical treatment beyond first aid.

The employer retains flexibility to determine whether an event or exposure in the work environment caused or contributed to an MSD.

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Q. How do I record hearing loss cases?

A. Standard threshold shift (STS) is an average change in hearing of 10 decibels (dB) or more from the baseline audiogram for the frequencies of 2000, 3000 and 4,000Hz in either ear, as defined by the Occupational Noise Exposure Standard, Rule 2. The recordkeeping rule requires an employer to record 10 dB shifts in an employee's hearing, if the level is at least 25 dB's above audiometric zero. STS that meet the recording criteria must be noted on the MIOSHA 300 Log in column M-5.

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Q. What are the requirements for employee involvement?

A. The standard requires employers to establish a procedure for employees to report injuries and illnesses (that informs) employees how to report.  Employees are allowed to access the MIOSHA Form 301 to review records of their own injuries and
illnesses.

Employee representatives have access to those parts of the MIOSHA Form 301 relevant to the employees they represent.  Employee representatives are given access only to the portion of Form 301 that contains information about the injury or illness, while personal information about the employee and his or her health care provider is withheld.

The standard also informs employers that the MIOSH Act prohibits employers from discriminating against employees who do report.

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Q. How do I decide whether an injury or illness is work-related if the employee is on travel status at the time the injury or illness occurs?

A. Injuries and illnesses that occur while an employee is on travel status are work-related if, at the time of the injury or illness, the employee was engaged in work activities "in the interest of the employer."

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Q. Are company parking lots considered part of the employer's work premises?

A. The rule includes company parking lots and access roads in the definition of "establishment."

Generally, once the employee is out of the vehicle, injuries and illnesses occurring in parking lots and on access roads are considered work-related (such as accidents at loading docks, snow removal, slips and falls, assaults, etc.) and must be recorded on the company's log if they meet the other recording criteria.

The rule excludes injuries and illnesses occurring while employees are commuting to or from work.

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Q. Are motor vehicle accidents recordable?

A. Motor vehicle accidents that are work-related are recordable. A motor vehicle accident is: a motor vehicle vs. a motor vehicle, or a motor vehicle vs. a person.

A motor vehicle accident that occurs in the company parking lot or on the company access road is not recordable if the injury occurred during the employee's commute.

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Q. What about employer-controlled recreational facilities?

A. Company recreational facilities are generally not considered part of the employer's premises for MIOSHA recordkeeping purposes, unless the employee was engaged in some work-related activity or was required by the employer to participate in a recreational program.

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Q. What if our company has multiple facilities?

A. Employers must keep a separate MIOSHA Form 300 for each establishment.  However, the records may be kept at a central location.  Employers must be able to produce and send the records from the central location to the establishment within four hours, when they are required to provide the records to a government representative.

A separate MIOSHA Form 300A Summary must be posted in each establishment.  For example, a school district may keep central records, but must post the MIOSHA Form 300A at each school (garage, library building, etc.)

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Q. Who certifies the MIOSHA Form 300A?

A. A company executive must certify the MIOSHA Form 300A Summary. A company executive is the owner, officer of the corporation, highest-ranking official working at the establishment, or immediate supervisor of the highest-ranking official. The summary must be signed and dated by the employer or whoever is delegated responsibility.

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Q. Is it true all fatalities must be reported within eight hours to MIOSHA?

A. YES. An employer is required by law to notify MIOSHA within eight hours. Heart attacks at work which result in a fatality fall within the reporting requirements.

A telephone line for reporting fatalities is available 24 hours a day by calling the Michigan Occupational Safety & Health Administration: 800-858-0397.

All work-related in-patient hospitalizations of one or more employees,  work-related amputations, or loss of an eye must be reported within 24 hours. The telephone number for these types of injuries is 844-464-6742.

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How can I get more information on recordkeeping?

The examples given are guidelines to help clarify common problem areas.  If you encounter recording problems, use good sound judgment and record the case under what you feel is the proper category.  A case that is recorded under the wrong category can easily be corrected. The important thing to remember is to RECORD ANY CASE YOU FEEL MIGHT BE RECORDABLE; AFTERWARDS SEEK CLARIFICATION AND ASSISTANCE.

For detailed information on the recordkeeping standard, forms or training, check the Recordkeeping and Statistics section on our website www.michigan.gov/recordkeeping.

You can also call the MIOSHA Management Information Systems Section at 517-284-7788 for recordkeeping information and forms.  For copies of the recordkeeping standard, check the MIOSHA website or call the MIOSHA Standards Section at 517-284-7740.  For information on the recordkeeping seminars and other training opportunities, call the MIOSHA Consultation Education and Training (CET) Division at 517-284-7720.

MIOSHA Severe Injury Reporting: 844-464-6742

Michigan Department of Licensing and Regulatory Affairs
Michigan Occupational Safety & Health Administration
530 W. Allegan Street, P.O. Box 30643
Lansing, Michigan 48909-8143

517-284-7778
MIOSHA/CET #0128 (Rev. 08/15)