As stated in the OSHA Small Business Handbook, “The primary purpose of OSHA-required recordkeeping is to retain information about accidents that have happened to help determine the causes and develop procedures to prevent a recurrence.  Importantly, good recordkeeping will be evidence of “good faith in reducing any penalties from OSHA inspections…” (Handbook, page 11).

Requirements: Maintaining and Posting Records

Records must be maintained at the worksite for at least five years. Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year. Also, if requested, copies of the records must be provided to current and former employees, or their representatives.

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Five (5) Steps in OSHA Injury and Illness Recordkeeping

The OSHA Small Business Handbook identifies five (5) steps in  injury and illness recordkeeping system (Handbook, page 13):

1. Obtain a report on every injury or job-related illness requiring medical treatment (other than basic first aid).
2. Record each injury or job-related illness on OSHA Form 300 (Log of Work-Related Injuries and Illnesses) using the instructions provided.
3. Prepare a supplementary record of occupational injuries and illnesses for recordable cases on OSHA Form 301 (Injury and Illness Incident Report).
4. Every year, prepare an annual summary using OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). Post it no later than February 1, and keep it posted until May 1. A good place to post it is next to the OSHA Workplace Poster.
5. Retain these records for at least five (5) years.

In addition to the injury and illness reporting and recordkeeping requirements, other OSHA standards also create recordkeeping requirements.  The Handbook offers a helpful, but not all-inclusive “self-inspection” checklist (Handbook, page 19).

Electronic Submission of Records

The OSHA Injury Tracking Application (ITA) is accessible from the ITA launch page, where you can provide the Agency your OSHA Form 300A information. The date by which certain employers are required to submit to OSHA the information from their completed Form 300A is March 2nd of the year after the calendar year covered by the form.

Severe Injury Reporting

Employers must report any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization of a worker within 24 hours.

• Learn details and how to report online or by phone.

OSHA 10-hour or 30-hour training programs are in-depth certification courses, created by OSHA and administered by government authorized trainers. The 10-hour class is intended to provide workers with awareness of common job-related safety and health hazards, while the 30-hour class is more appropriate for supervisors or workers with some safety responsibility.

Is OSHA training required in your state? Take a look at the specific requirements for your state.

OSHA 10-hour Construction Curriculum

The mandatory curriculum must include an introduction to OSHA, personal protective equipment and lifesaving equipment, health hazards in construction and the “focus four hazards” which are falls, electrocution, struck by, and caught in/or between. The elective topics include cranes, excavations, material handling, scaffolds, stairways, ladders, hand and power tools, and one hour of optional material covering industry hazards or an expansion on required topics.

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OSHA 30-hour Construction Curriculum

The mandatory curriculum must mirror that of the 10-hour construction curriculum but the time required is increased. The elective topics are expanded in the 30-hour training to 12 hours and they may include safety information about concrete and masonry construction, confined space entry, ergonomics, excavations, fire protection, motor vehicle safety, powered industrial vehicles, safety and health programs, steel erection, welding and cutting, foundations for safety leadership, and 3 hours of optional material covering industry hazards, policies, and an expansion on required topics.

States that require 10hr/30hr OSHA Outreach training:

Connecticut, Massachusetts, Missouri, Nevada, New Hampshire, New York, Pennsylvania, Rhode Island, and West Virginia

Connecticut

• All employees who perform work on any public building project paid for in whole or part by state funding, or any of its agencies, where the total cost is over $100,000. This law went into effect in 2007.
• Each contractor needs to furnish proof that all employees have taken the OSHA 10 hour Construction Course within 30 days of being awarded the contract. Employees who have not completed the course are subject to removal from the worksite.
• The OSHA 10 hour Construction Course must also be retaken every 5 years.

Reference: Connecticut General Statutes – Section 31‐53b – Construction Safety

Missouri

• Missouri Construction Safety Training Act requires all contractors and subcontractors who enter into contracts with public bodies for construction of public works to train their on-site employees regarding the potential hazards they may encounter. The law went into effect in 2009.
• Any employee found on a work site subject to this section without documentation of the successful completion of an OSHA 10 Hour course shall be afforded 20 days to produce such documentation before being subject to removal from the project.
• It is also the employer’s responsibility to make sure all their employees have their certification card and turn in proof to the contracting agency before the job starts. The employer can be fined for allowing an employee onsite who does not have a valid OSHA 10 hour certification card.

References:

• Missouri Statutes – Chapter 292 – Health and Safety of Employees | Section §292.675
• Missouri Department of Labor and Industrial Relations – Required Construction Training

Massachusetts

• All employees to be employed at a worksite needs to complete the OSHA 10 hour construction course before beginning work on the worksite. The law went into effect in 2004.
• Any employee found on a worksite subject to this section without documentation of successful completion of the OSHA 10 hour course shall be subject to immediate removal.
• The Massachusetts law specifically says “at least 10 hours” – so an OSHA 30 hour construction course would also enable the worker to meet these requirements.
• It is also the employer’s responsibility to make sure all their employees have their certification card and turn in proof to the contracting agency before the job starts. The employer can be fined for allowing an employee onsite who does not have a valid OSHA10 hour certification card.
• The OSHA 10 hour Construction Course must also be retaken every 5 years.

Reference:  Massachusetts General Laws – Chapter 30: Section 39S

New Hampshire

• Any person who signs a contract to work on a construction, reconstruction, alteration, remodeling, installation, demolition, maintenance, or repair of any public work or building by a state agency or municipality with a total project cost of $100,000 or more. The law went into effect in 2007.
• Employees who fail to obtain their OSHA 10 Hour Card after 15 days of starting work, will be removed from the jobsite.
• Employers can face penalties up to $2,500 and a civil penalty of $100 per employee for each day of noncompliance.

References:

• Title XXIII: Labor – Chapter 227 Safety and Health of Employees – 277:5-a Occupational Safety and Health Administration Certification;
• New Hampshire Department of Labor – Safety

New York

• New York State Labor Laws – Chapter 282 – Labor Law §220-h took effect on July 2008. All public works contracts for New York state and municipal construction jobs of $250,000 or more require certification that all employees performing work under the contract will have successfully completed an OSHA 10-hour construction course.
• New York City OSHA Laws – NYC Int. 790-A of Local Law 48 of 2008 requires all construction workers to complete an OSHA Outreach 10 hour course within the previous 5 calendar years.
• New York City OSHA Laws also requires all site supervisors complete an OSHA Outreach 30 hour training course.
• Renewal: Once you have completed OSHA 10 training for work on Article 8 public work projects, New York State does not require renewal. However, New York City does require renewal of the training every 5 years.
• By December 1, 2018, workers at job sites that require a Site Safety Plan (which includes sites that must designate a Construction Superintendent, Site Safety Coordinator or Site Safety Manager) and must receive a minimum of 40 hours of training. That means workers must have the OSHA 10 and 30 hours construction training.

Reference:  New York State – Department of Labor – OSHA 10 Information

Nevada

• All construction workers in the state to undergo a 10-hour safety training course (OSHA-
• 10) developed by the U.S. Labor Department’s Occupational Safety and Health Administration (OSHA) at least once every five years. The training must be completed no more than 15 days of being hired.
• All supervisors on a construction site to undergo a 30-hour safety training course (OSHA-30) approved by OSHA at least once every five years. The training must be completed no more than 15 days of being hired.
• If an employee or supervisor does not gain 10 or 30-hour certification, then their employment must be terminated or suspended. Employers who fail to terminate or suspend employees are subject to administrative fines and penalties.

Reference: Nevada Assembly Bill No. 148 (PDF)

Pennsylvania – Philadelphia

• All workers directly performing construction or demolition activities for which permits have been issued are required to complete OSHA 10 safety training or an approved equivalent. (Philadelphia Code, Title 4, Subcode A, Section A – 1001.4). This requirement applies to all employees of licensed contractors (including plumbing, electrical, fire – suppression and warm – air contractors) AND State – registered Home Improvement Contractors. Workers will be required to furnish proof of required safety training to Department of Licenses and Inspections officials upon request.
• All contractors licensed under Section 9 – 1004 of the Philadelphia Code must employ at least one supervisory employee who has completed OSHA 30 safety training, or approved equivalent, within the past 5 years. (Philadelphia Code, Section 9 – 1004(4)(c.1)). Licensed plumbing, electrical, fire suppression, and warm – air contractors are not required to employ an OSHA 30 supervisory employee. Identification of a supervisory employee and proof of training will be required for all new Contractor License applications made after September 30, 2015 and for the renewal of all Contractor Licenses set to expire on or after March 31, 2016.

References:

• City of Philadelphia OSHA Safety Training Requirements (PDF)
• City of Philadelphia License and Inspections – Safety Training Info Sheet (PDF)

Rhode Island

• All workers who perform work on municipal and state construction projects with a total project cost of one $100,000 of more to OSHA10-hour certification. Workers are also to carry the card on their person at all times while work is actually being performed.
• Any employee required to complete the OSHA 10-hour construction safety program who has not completed the program will be subject to removal from the worksite, if the employee does not provide documentation of having completed such program by the 15th day after the date the employee is found to be in noncompliance.
• The state may also assess a civil penalty of up to $2,500; in addition, such an employer shall be assessed a civil penalty of $100 per employee for each day of noncompliance.

Reference: Rhode Island General Laws – Title 37. Public Property and Works – §37-23-1 Safety awareness program required. (PDF)

West Virginia

• All workers who perform work on a public project costing more than $50,000 or more, requires each employee onsite to have their OSHA 10 hour certification card.
• Any employee required to complete the OSHA 10-hour construction safety program who has not completed the program will be subject to removal from the worksite, if the employee does not provide documentation of having completed such program by the 21st day after the date the employee is found to be in noncompliance.
• The state may also assess a civil penalty of up to $1,000; in addition, such an employer shall be assessed a civil penalty of $100 per employee for each day of noncompliance.

Reference:  West Virginia Code – Chapter 21 Labor – Article 3. Safety and Welfare of Employees – §21-3-22. OSHA construction safety program.

Together, these hazards are often referred to as the “Focus Four” because dedicated focus should be given to preventing accidents caused by these hazards. Eliminating these accidents would save 500 lives per year, according to OSHA.

The “Focus Four” includes: Falls, Caught in-between, Electrocutions, and Struck by.

Falls

Falls account for 40 percent of construction workers fatalities, making them the most dangerous of the focus four hazards:

• Fall protection. Use fall protection when working at heights of six feet or more. Remember that regardless of the fall distance, employers must provide fall protection when employees work over dangerous equipment and machinery. Inspect fall protection before each use for broken parts, stress cracks, frayed or kinked ropes and other damage.
• Walking/working surfaces. Guard skylights, ramps, edges, wall openings, open-sided floors and other walking/working surfaces.
• Scaffolds. Scaffolds should be designed by a competent person and include guardrails along open sides and ends. Inspect guardrails, connectors, fastenings, footings, tie-ins, bracing and planking for damage. Remove damaged scaffolds from service immediately, and never exceed a scaffold’s intended load or rated capacity.
• Ladders. Inspect ladders for damage and slippery rungs. Maintain three-point contact when working on ladders, and keep your body between the rails at all times to avoid over-reaching. Finally, leverage NIOSH’s ladder safety app to help employees set up and use ladders properly.
• Housekeeping. A clean, orderly workplace promotes productivity and reduces the risk of slips, trips and falls. Keep walkways, stairs and exits clear of merchandise, supplies and cleaning products. Clean up spills as soon as possible, and use “Caution: Wet Floor” signs in the meantime. In wet weather, use slip-resistant floor mats to keep people’s feet on solid ground.

Struck-by injuries

There are four common causes of struck-by injuries: flying, falling, swinging and rolling objects.

Flying objects. Any time workers use power tools and do tasks that require pushing, pulling and prying, they are at risk of being struck by flying objects. For example, a nail fired from a nail gun might travel through a wall and hit another worker in the eye:

• Wear eye and face protection when required.
• Make sure machine guards are in place.
• Do not operate power-actuated tools without the necessary training.
• Reduce compressed air used for cleaning to 30 psi.

Falling objects. We are at risk from falling objects when we work underneath cranes, scaffolds and other overhead work. For example, a New Jersey man recently died when a tape measure fell from 400 feet above and hit him in the head:

• Wear your hard hat.
• Use toe boards and debris nets to catching falling objects.
• Avoid working underneath loads being moved.
• Do not exceed the lifting capacity of cranes and hoists.
• Be aware of unbalanced loads.

Swinging objects. Mechanically lifted materials can swing, twist or turn and strike workers:

• Stay out of the swing radius of cranes, backhoes and other equipment.
• Rig loads properly to prevent slippage.
• If a worker on foot must control the load, use a tag line.
• Use extra caution on windy days, when loads are more likely to swing, twist or turn.

Rolling objects. One of the most common accidents involving rolling objects is when a worker is hit by a vehicle in a work zone:

• Do not drive a vehicle in reverse with an obstructed rear view unless it has an audible reverse alarm or another worker signals it is safe.
• Set parking brakes when vehicles and equipment are parked, and chock the wheels if they are on an incline.
• Wear high-visibility clothes near equipment/vehicles, make sure drivers can see you and avoid equipment blind spots.
• Stay behind protective barriers in work zones whenever possible.

Electrical hazards

The primary causes of electrical hazards are contact with overhead powerlines, contact with energized sources and improper use of extension cords.

Overhead powerlines. Overhead and buried powerlines carry high voltage that can cause electrocutions, severe burns and falls:

• Stay at least 10 feet away from overhead powerlines.
• Use a spotter if it is hard for workers operating the cranes, scissor lifts or other equipment to see overhead power lines.
• Unless you know otherwise, assume overhead lines are energized. Ask the utility company to de-energize lines and identify buried power lines in the area.
• Use non-conductive wood or fiberglass ladders when working near power lines.

Energized sources. Live parts, damaged or bare wires and defective equipment and tools can cause electrical shocks and burns:

• Isolate electrical parts with guards, barriers or covers.
• Ground power supply systems, electrical circuits and electrical equipment, and use ground fault circuit interrupters.
• Use power tools as designed, and inspect tools before using them. If a tool shocks you or smokes and sparks when you turn the power on, take it out of service and notify your supervisor immediately.
• Follow lockout/tagout procedures.

Extension cords. The normal wear and tear on extension and flexible cords can loosen or expose wires, creating a hazardous condition:

• Do not misuse power cords. Cords that are kinked, tied in a knot, crushed, cut or bent cannot insulate electrical current safely.
• Inspect extension cords for damaged insulation, exposed wires, frayed ends and missing or unsecure prongs. If you find a damaged cord, take it out of service immediately. Don’t try to repair it by taping or splicing it.
• Do not make unauthorized modifications to your extension cords.
• Do not run extension cords through areas where they are likely to get wet or damaged.

Caught-in or -between hazards

Caught-in or -between injuries happen when workers are crushed between objects. Common examples include cave-ins, workers being pulled into machinery and workers crushed between rolling, sliding or shifting objects.

Cave-ins:

• Do not work in an unprotected trench that is 5 feet deep or more.
• Enter or exit a trench or excavation only by using a ladder, stairway or properly designed ramp that is placed within the protected area of the trench. Do not work outside the protection system.
• Set spoils and equipment at least two feet back from the excavation. If that isn’t possible, temporarily store them somewhere else.

Caught in machinery:

• Never remove a safety guard when a tool is being used.
• Follow lockout/tagout procedures for clearing jams and cleaning machines.
• Do not wear loose clothing or jewelry that can be caught in moving parts.
• Tie long hair up to keep it out of machines.

Crushed between objects:

• Know where heavy equipment is at all times, and keep a safe distance from it.
• Never place yourself between moving materials and an immovable structure, vehicle or stacked materials.
• Make sure all loads carried by equipment are stable and secure.
• Wear a seatbelt to avoid being thrown from a vehicle and crushed by the vehicle if it tips over.
• Make sure forklift operators are trained and certified.
• Enforce a traffic control plan, and ensure workers wear high-visibility clothing that meets ANSI standards.

Additional Resources

• Introduction to the Construction Focus Four Outreach Training Packet [PDF]
• OSHA Focus Four

Businesses spend $170 billion a year on costs associated with occupational injuries and illnesses – expenditures that come straight out of company profits. But workplaces that establish safety and health management systems can reduce their injury and illness costs by 20 to 40 percent. In today’s business environment, these costs can be the difference between operating in the black and running in the red.

Let us consider why OSHA important and good for businesses:

• OSHA works with science and engineering experts, with input from industry, to develop standards for safety and health in the workplace.
• Because employers are legally responsible for providing a safe and healthful workplace for employees, OSHA enforces these standards – firmly and fairly.
• Recognizing that most employers want to comply with the law, OSHA has designed many tools and services to help businesses succeed.

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• Know Your Rights – Under Federal law, you are entitled to a safe workplace. Training also plays a key role in the prevention of accidents.
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OSHA Good for Employer and Employees

For employers, the financial toll of illnesses, injuries and fatalities on the job is enormous. Small and medium-sized businesses are especially vulnerable to the impact of workplace hazards –

First, because the resulting costs hit the slim budgets of small businesses very hard; and second, owners of small businesses often work side-by-side with their family members and other employees – making a worksite tragedy immediate and deeply personal.

For employees, on the job hazards can have a terrible impact. According to a study in the American Journal of Industrial Medicine, a single workplace illness or injury costs an employee and his or her family on average $8,000 – out of pocket – often forcing them to dip into savings or default on payments.

As a result, these employees are much more likely to lose their homes, their cars, and their health insurance. Taking steps to keep employees safe reduces this spiral of debt – and, of course, prevents a lot of suffering, strain and stress on thousands of lives.