OSHA Recordkeeping Handbook - Msabc.net

2. Number of employees and hours worked....The final rule requires employers to include in theAnnual Summary (the OSHA Form 300-A) the annualaverage number of employees covered by the Log andthe total hours worked by all covered employees....OSHA’s view is that the value of the total hoursworked and average number of employees informationrequires its inclusion in the Summary, and thefinal rule reflects this determination. Having thisinformation will enable employers and employees tocalculate injury and illness incidence rates, which arewidely regarded as the best statistical measure forthe purpose of comparing an establishment’s injuryand illness experience with national statistics, therecords of other establishment, or trends over severalyears. Having the data available on the Form 300-Awill also make it easier for the employer to respondto government requests for the data, which occurswhen the BLS and OSHA collect the data by mail,and when an OSHA or State inspector visits the facility.In particular, it will be easier for the employer toprovide the OSHA inspector with the hours workedand employment data for past years.......[T]he rule does not require employers to useany particular method of calculating the totals, thusproviding employers who do not maintain certainrecords--for example the total hours worked bysalaried employees--or employers without sophisticatedcomputer systems, the flexibility to obtain theinformation in any reasonable manner that meets theobjectives of the rule. Employers who do not havethe ability to generate precise numbers can use variousestimation methods. For example, employerstypically must estimate hours worked for workerswho are paid on a commission or salary basis.Additionally, the instructions for the OSHA 300-ASummary form include a worksheet to help theemployer calculate the total numbers of hoursworked and the average number of.3. Extended posting period.The final rule’s requirement increasing the summaryForm 300-A posting period from one month to threemonths is intended to raise employee awareness ofthe recordkeeping process (especially that of newemployees hired during the posting period) by providinggreater access to the previous year’s summarywithout having to request it from management.......OSHA has decided to adopt a 3-month postingperiod. The additional posting period will provideemployees with additional opportunity to review thesummary information, raise employee awareness ofthe records and their right to access them, and generallyimprove employee participation in the recordkeepingsystem without creating a “wallpaper” postingof untimely data. In addition, OSHA has concludedthat any additional burden on employers will beminimal at best and, in most cases, insignificant. Allthe final rule requires the employer to do is to leavethe posting on the bulletin board instead of removingit at the end of the one-month period.The final rule thus requires that the Summary beposted from February 1 until April 30, a period of threemonths; OSHA believes that the 30 days in Januarywill be ample, as it has been in the past, for preparingthe current year’s Summary preparatory to posting.4. Review of the records.The provisions of the final rule requiring the employerto review the Log entries before totaling them forthe Annual Summary are intended as an additionalquality control measure that will improve the accuracyof the information in the Annual Summary, whichis posted to provide information to employees and isalso used as a data source by OSHA and the BLS.Depending on the size of the establishment and thenumber of injuries and illnesses on the OSHA 300Log, the employer may wish to cross-check with anyother relevant records to make sure that all therecordable injuries and illnesses have been includedon the Summary. These records may include workers’compensation injury reports, medical records,company accident reports, and/or time and attendancerecords.OSHA did not propose that any auditing or reviewprovisions be included in the final rule....In the final rule, OSHA has not adopted regulatorylanguage that requires formal audits of the OSHAPart 1904 records. However, the final rule doesrequire employers to review the OSHA records asextensively as necessary to ensure their accuracy.The Agency believes that including audit provisionsis not necessary because the high-level certificationrequirement will ensure that recordkeeping receivesthe appropriate level of management attention.......OSHA has not required records audits in thefinal rule because the Agency believes that the combinationof final rule requirements providing foremployee participation (section 1904.35), protectingemployees against discrimination for reporting workrelatedinjuries and illnesses to their employer (section1904.36), requiring review by employers of therecords at the end of the year, and mandating twolevel certification of the records will provide the qualitycontrol mechanisms needed to improve the qualityof the OSHA records.§1904.32OSHA RECORDKEEPINGHANDBOOK137