For the past 40 years, OSHA has required the majority of employers with ten (10) or more employees to maintain records of workplace illness, injury, or death. Those same employers are also required to post the annual summary (300 logs) from February 1, through April 30, of the subsequent year (i.e., 2014’s summary is to be posted in 2015).
OSHA recently updated the recordkeeping rules to include a number of industries never required to report in the past. That same update also requires the electronic submission of injury, illness and death data to OSHA.
Among the industry sectors that are now required to maintain, post, and submit information concerning occupational injuries, illnesses, and deaths are the following:
Lessors of Residential Buildings and Dwellings
Lessors of Nonresidential Buildings (except Miniwarehouses)
Lessors of Miniwarehouses and Self-Storage Units
Lessors of Other Real Estate Property
Activities Related to Real Estate
Real Estate Property Managers
Residential Property Managers
Nonresidential Property Managers
Offices of Real Estate Appraisers
Other Activities Related to Real Estate
Facilities Support Services
Services to Buildings and Dwellings
Exterminating and Pest Control Services
Carpet and Upholstery Cleaning Services
Other Services to Buildings and Dwellings
Recordkeeping citations are frequently issued and often costly due to the number of incidents that are either reported incorrectly or not reported at all. Those citations can range from $1,000 to $7,000 per violation (which can be as simple as misclassifying an injury as an illness). We closely monitor this and can offer your company guidance and assistance with respect to developing a recordkeeping program and operating it in a fashion that is compliant with OSHA regulations.