05 Jan Cal/OSHA Recordkeeping and Reporting

Cal/OSHA Recordkeeping and Reporting

The California Division of Occupational Health (Cal/OSHA) requires recordkeeping and reporting about safety in the workplace. Required records include the OSHA 300 Log and documents about safety hazard analysis, inspections, and accident investigations. Hazard-specific regulations such as asbestos, diving, mining, etc. also have additional recordkeeping requirements. Keeping track of recordkeeping requirements is a challenge.

The OSHA 300 log is probably the most familiar to workers and employers. It records all work-related deaths along with injuries and illnesses that require more than first aid treatment. An annual summary of injuries and illnesses is required to be posted in the workplace. Some small businesses (less than 10 employees) and certain industries may have limited exemptions from this recordkeeping requirement. All Employers must report to Cal/OSHA any serious injury, illness or death of an employee immediately, but no longer than 8 hours after the employer knows or with diligent inquiry would have known.  If the employer can demonstrate that exigent circumstances exist, the time frame for the report may be made no longer than 24 hours after the incident.

Cal/OSHA also requires employers to keep records on hazard evaluations and the corrective actions taken to reduce or control safety risks in the workplace. Job hazard analysis (JHA) evaluates a worker’s job tasks, tools, equipment, and procedures to determine the level of safety risk and how to control it. Also examine and plan for hazards associated with new tools, equipment, chemicals, tasks, and work environments. Keeping records of these hazard evaluations and risk reduction efforts can document that a business has diligently worked to protect workers. Communicate with employees about these evaluations to make them aware of job hazards and help them work safer.

Periodic workplace safety inspections identify hazards in the workplace. Keep records of the identified hazards and the actions that were taken to correct them. Investigate all employee accidents and near misses to determine the root cause of the accident. Document any corrective actions taken to reduce the risk of further accidents. Take the same steps when investigating employee complaints by recording the investigation process and any necessary corrective actions. Communicate the results of inspections, accident investigations, and complaint response to employees.

Safety training is a key component in making employees aware of the risks and hazards involved with their work tasks along with the appropriate work practices and personal protective equipment that keeps them safe. General safety training may include ergonomics, first aid, CPR, and injury and illness prevention. Specific work task and hazards safety training can target chemical use, fall protection, lockout/tagout, etc. Keep records of all employee safety training.

With all of this recordkeeping, it may be confusing about how long to keep safety records. Storage time requirements range between 1, 3, and 5 years. Check the specific regulations that apply to your industry, but as a best practice, store safety and training records for 5 years. Note that some regulations have separate recordkeeping requirements and timelines. For example, asbestos training records are required to be kept one year past the last date of employment of a worker. Employee medical records need to be kept for the length of employment plus 30 years.

Cal/OSHA posting requirements ensure that you communicate about safety and hazards in the workplace. Every place of employment should have the Job Safety and Health Protection poster placed in a prominent area. Copies of all Cal/OSHA citations must be posted for 3 days or until the violations are corrected. Finally, post notices of Cal/OSHA investigations, complaints, and the required employer response for 3 days.

Employers must provide their employees access to safety records within a reasonable timeframe (usually 7 days) and must notify employees when monitoring indicates that they have been exposed to a hazard. Employees have a right to information and records about hazardous chemicals in the workplace (Safety Data Sheets), hazard exposure monitoring, and their own safety, personnel, and medical records. Employees also have the responsibility to report all workplace hazards, illnesses, injuries, accidents, and near misses so they can be evaluated and prevented in the future.

Comply with the law; go on record and document your safety efforts and statistics.