The Occupational Safety and Health Administration’s (OSHA) 
recordkeeping requirements have been in place since 1971 (29 Code of Federal Regulations CFR Part 1904). The requirements were updated in 2002 to make it easier for employers to comply. OSHA has again updated the recordkeeping rule for 2015 to include two key changes.
The first change updates the list of industries that are exempt from the requirement to routinely keep OSHA injury and illness records due to relatively low occupational injury and illness rates. As of January 1, 2015, exempt industries will be based on the North American Industry Classification System (NAICS). As a result of this movement to the NAICS classification, some industries that were previously covered will no longer be covered and some industries that were not previously covered will now be covered.
The second change expands the list of severe work-related injuries and illnesses that all covered employers must report to OSHA. This revision retains the current requirement to report all fatalities within 8 hours and adds the requirement to report all inpatient hospitalizations, amputations, and loss of an eye within 24 hours. Further, all related information must be properly recorded on the appropriate OSHA form.
Scope of Changes
Employers are classified by OSHA’s injury and illness recordkeeping requirements into one of three groups:
- Employers regularly exempt from OSHA recordkeeping include small businesses with fewer than 11 full- or part-time employees during the previous calendar year and employers classified in low-hazard industries. These employers are required to report all inpatient hospitalizations and fatalities as required by 29 CFR 1904.39. In addition, if the employer is notified in writing by OSHA to participate in a statistical survey, the employer must maintain injury and illness records.
- Employers exempted from preparing and maintaining injury and illness records include industries listed in Appendix A of Subpart B of the revised recordkeeping standard.
- Employers that are not classified under either of the two groups mentioned above are required to comply with all of the guidelines of 29 CFR 1904.
It is important to know your NAICS code and whether it is exempted in Appendix A of the revised rule. For more information check on either link below.
OSHAs_Recordkeeping_Exceptions_Fact_Sheet
OSHA_Recordkeeping_FactSheet_Jan_2015
Written by Jack Fearing.