UVI's Safety in Paradise Hosts Important Seminar Explaining OSHA Record-Keeping Requirements Before March Deadline

  • Kyle Murphy
  • January 24, 2021
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The University of the Virgin Islands' Safety in Paradise (SIP) program on Friday explained why Occupational Safety and Health Administration (OSHA) reporting is important and provided details on how to fill out the required documents.

Patrica Williams-Anderson, who has over 25 years of experience working in safety and health professions, led the presentation and was joined by other consultants from UVI’s SIP program during the hour-long webinar.

Reporting incidents at the workplace helps managers and employees identify potential areas of concerns. Reporting also alerts OSHA of industries, companies, and organizations of potential equipment/machinery malfunctions or hazards.  

Marciel Flores Diaz, SIP consultant for St. Thomas, highlighted funding opportunities that result from reporting. “As much as you share the information about what is going on in your organizations, we can use that information to request OSHA funding,” he said.

Ms. Flores Diaz also encouraged companies and organizations that are not required to keep records to still do so. “You will see what is the trend in your operation and be able to identify areas of improvement," she said.

The Bureau of Labor Statics (BLS) record-keeping is different from OHSA record-keeping because the latter is a national standardized system and the information obtained helps to evaluate workplace safety, while BLS requirements can vary from each state and territory. 

Ms. Williams-Anderson addressed why she thinks some incidents go unreported. “At times employers fail to log incidents because they are fearful of potential negative implications, and employees neglect to inform their employers because they are in fear of retribution," she said. "It’s been my experience that not every injury or illness is an employer's fault or due to employee's negligence. I strongly recommend that employers log all their injuries and illnesses.”  

Injuries and illnesses that are work-related and meet a certain severity criteria must be reported. That criteria is any work-related incident that result in fatality, loss of consciousness, days away from work, restricted work or transfer to another job. 

Days away from work include weekends and all days that the employee was unable to work, not just days they were scheduled. If these days exceed 180, the employer can simply write 180 in the spot on the form for days unable to work. Restricted work was defined as the employee being unable to work a full shift, or an employee being unable to perform all the regularly assigned duties at least once during a work week. If a case involves both days unable to work and restricted work, an accurate count must be kept for both.   

Employers are required to report incidents that result in fatalities within 8 hours and all incidents that require hospitalizations, amputations and loss of an eye within 24 hours. These incidents can be reported by calling OSHA at 1-800-321-6742. 

Based on OSHA standards, incidents that require “first aid only” are not required to be reported. First aid is defined as using wound coverings, using any non-rigid means of support, using temporary immobilization devices while transporting an accident victim, using eye patches, removing splinters or foreign material by simple means and drinking fluids for relief of heat and stress.

COVID-19 is a reportable illness if the case is confirmed based on the U.S. Centers for Disease Control and Prevention (CDC) definition. 

The OSHA record keeping forms are OSHA 300 Form; a log of work-related injuries and illness; OSHA 300A document, a summary of work-related injuries and illnesses document; and OSHA 301 Form, an injury and illness report document. These forms can be found here.

Businesses are required to post only the 300A summary of work-related injuries and illnesses from the previous years, where they would normally post employee-only notices from at least February 1 to April 30. These records must be maintained and  updated as incidents occur and be available for review within four hours of an OSHA request. Businesses are not required to send to OSHA unless asked to do so. Records for up to five years can be requested by OSHA.  

Employers are required to adhere to these requirements unless they have fewer than 10 employees who are identified as low-hazards industries as classified by the North American Industrial Classification System code. Examples of these types of business that were stated in the presentation include restaurants, banks and medical offices.

Businesses that have over 250 employees are establishments where employees are classified in specific industries. These large businesses are also required to complete the online Injury Tracking Reporting Application by March 2. That form can be found here.

These documents can only be signed by the owner of the company, officer of a corporation or the highest ranking official of an establishment.   

From October 1, 2019 - September 31, 2020 the five most common industries in the Virgin Islands that reported incidents were contractors, hotels, construction, communication and retail stores.   

UVI's Safety In Paradise is a free and confidential OSHA consultation service provided by the institution's Center for Excellence and Leadership and Learning (UVI CELL).  Services are available at no cost to private-sector employers and nonprofit organizations, according to a release issued before the Friday webinar. 



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