Cover image for OSHA 2002 recordkeeping simplified
OSHA 2002 recordkeeping simplified
Roughton, James E.
Personal Author:
Publication Information:
Amsterdam ; Boston : Butterworth-Heinemann, [2003]

Physical Description:
xxiii, 471 pages : illustrations ; 24 cm
Format :


Call Number
Material Type
Home Location
Item Holds
T55 .R695 2003 Adult Non-Fiction Central Closed Stacks

On Order



The Occupational Safety and Health Administration (OSHA) has updated their recordkeeping requirements for the first time since 1971. This results in a significant number of changes for every employer with ten or more employees, which can often cause confusion and failure to comply. OSHA 2002 Recordkeeping Simplified goes beyond the explanation that OSHA supplies to provide an easy understanding of these new requirements.

OSHA 2002 Recordkeeping Simplified provides an easy to follow format that allows all those in charge of recordkeeping to comply with the updated standards. The book follows the standards as OSHA provides them and adds commentary in order to explain and simplify. Jim Roughton provides a comparison of the old standards to the new to allow for an easier transition.

The text is divided into several major subject sections. First the requirements are addressed to outline new elements compared to the current requirements. Next the supplement information for each subject area is divided into several parts: The first part reviews the relevant sections of the requirement and provides the basic concepts of how recordkeeping works; the second part provides answers to most frequently asked questions about recording and reporting of occupational injuries and illnesses. These questions and answers elaborate on the basic recordkeeping concepts and are further defined in each section. In addition, a series of flow diagrams are used to track the flow of the standard and examples of citations are offered through case histories.

Author Notes

James Roughton MS, CSP, CRSP, R-CHMM, CIT, CET, Certified Six Sigma Black Belt

James is an experienced Safety Professional with an in-depth knowledge in the use of Social Media to help improve productivity. He is accomplished speaker, author, and writer, develops and manages his own web sites that provide a resource network for small businesses at Three of his most notable books include, Safety Culture: An Innovative, Leadership Approach, Developing an Effective Safety Culture: A Leadership Approach, and Job Hazard Analysis and A Guide for Voluntary Compliance and Beyond. He is an active board member and web master for the Georgia Conference - He is a past President of the Georgia of the ASSE; Past Chair - Gwinnett Safety Professionals, Past Adjunct Professor Safety Technology Lanier Tech, Georgia Tech, and currently adjunct Professor Columbia Southern University. He has received awards for his efforts and was named the Georgia Chapter ASSE Safety Professional of the Year 1998-1999, Project Safe Georgia Award, 2008, and received the Georgia Safety, Health, and Environmental Conference's Earl Everett distinguished Service Award, 2014.

Table of Contents

Prefacep. xi
Acknowledgmentsp. xix
Acronymsp. xxi
About the Authorp. xxiii
Introductionp. 1
Highlights and Major Changes to OSHA's Recordkeeping Rulep. 1
How Can I Tell If I Am Exempt?p. 4
Low-Hazard Industry Exemptionp. 4
What Is Important About Recordkeeping?p. 8
An Overview of What Has Changedp. 8
Overview of the New Formsp. 9
Work-Related Statusp. 9
Recording Criteriap. 10
Day Countsp. 11
Annual Summaryp. 11
Employee Involvement (Participation)p. 11
Protecting Privacyp. 12
Reporting Information to the Governmentp. 12
Provisions Delayedp. 12
How Can I Get More Information on Recordkeeping?p. 13
State Programsp. 13
Part I Understanding the Rulep. 15
1. Overview of the Final Regulationp. 17
Changes to the New Rulep. 17
Transition from the Old Rule to the New Rulep. 18
Changes in the Recording Criteriap. 19
Overview of the Final Regulationp. 24
New OSHA Instructionsp. 25
Recording and Reporting Requirementsp. 25
Enforcement Datep. 26
Summary of the New Recordkeeping Rulep. 26
Citations and Penaltiesp. 38
Recording Criteria for Cases Involving Medical Removalp. 39
Privacy Concern Cases--Employee Privacyp. 40
Physician or Other Licensed Health Care Provider's Opinionp. 41
Other Changesp. 42
2. Occupational Injury and Illness Recording and Reporting Requirements, Part 1904p. 48
Purpose--Subpart Ap. 51
Definitions, Section 1904.46, Subpart Gp. 51
Scope--Subpart Bp. 58
Partial Exemption for Employers with 10 or Fewer Employees, Section 1904.1p. 59
Partial Exemption for Establishments in Certain Industries, Section 1904.2p. 60
Keeping Records for More Than One Agency, Section 1904.3p. 63
Recordkeeping Forms and Recording Criteria--Subpart Cp. 63
Recording Criteria, Section 1904.4p. 64
Determination of Work-Relatedness, Section 1904.5p. 69
Determination of New Cases, Section 1904.6p. 85
General Recording Criteria, Section 1904.7p. 90
Additional Criteria, Sections 1904.8 through 1904.12p. 111
Reserved, Sections 1904.13 through 1904.28p. 119
OSHA 300 Forms, Section 1904.29p. 119
Other OSHA Injury and Illness Recordkeeping Requirements--Subpart Dp. 124
Multiple Business Establishments, Section 1904.30p. 124
Covered Employees, Section 1904.31p. 125
Annual Summary, Section 1904.32p. 126
Retention and Updating, Section 1904.33p. 130
Change in Business Ownership, Section 1904.34p. 131
Employee Involvement (Participation), Section 1904.35p. 131
Prohibition Against Discrimination, Section 1904.36p. 135
Variances from the Recordkeeping Rule, Section 1904.38p. 136
Providing Records to Government Representatives, Section 1904.40p. 138
Transition from the Former Rule--Subpart Fp. 139
Summary and Posting of the 2001 Data, Section 1904.43p. 139
Retention and Updating of Old Forms, Section 1904.44p. 139
Amended Part 1952p. 140
Reporting Fatality, Injury, and Illness Information to the Government--Subpart Ep. 141
Reporting Fatalities and Multiple Hospitalization Incidents to OSHA, Section 1904.39p. 141
Annual OSHA Injury and Illness Survey of Employers of 10 or More Employees, Section 1904.41p. 143
Requests from the Bureau of Labor Statistics for Data, Section 1904.42p. 146
OMB Control Number Under the Paperwork Reduction Act, Section 1904.45p. 146
Part II Programs that Support the Recordkeeping Rulep. 149
3. Conducting Effective Incident Investigationsp. 151
Root Causes Definedp. 151
Benefits of Root Cause Analysisp. 152
Incident Preventionp. 153
What Causes Incidents?p. 154
Elements of the Safety Systemp. 154
What Should Be Investigated?p. 155
Who Should Investigate an Incident?p. 158
Analysis of Patternsp. 159
Interviewing Injured Employeesp. 161
Interviewing Witnessesp. 161
Re-creating the Incidentp. 164
Determining Causep. 164
Corrective Action Plansp. 165
Problem-Solving Techniquesp. 166
Investigation Reportp. 167
4. The Benefits of Job Hazard Analysisp. 170
Why Do a JHA?p. 170
Assigning Responsibilityp. 172
Conducting a JHAp. 172
Breaking Down the Jobp. 173
Developing a Priority List of Tasksp. 175
Using Employee Participation to Develop Task-Specific JHAsp. 179
Reviewing the JHA Until Employees Understand the Hazards of the Jobp. 180
Developing an Action Plan to Identify Incidentsp. 180
5. Developing and Administering a Medical Surveillance Programp. 185
Why Do You Need a Medical Surveillance Program?p. 185
Who Should Manage the Medical Provider?p. 186
What Services Do You Need from a Medical Provider?p. 187
The Range of Medical Provider Functionsp. 188
Early Recognition and Treatmentp. 188
Protocols and Established Standardized Proceduresp. 190
Medical Provider Qualificationsp. 190
Evaluating the Qualifications of a Medical Providerp. 191
6. Employee Participationp. 194
Why Should Employees Be Involved?p. 194
Getting Employee Participation Startedp. 197
Usual Forms of Employee Participationp. 201
What Management Must Dop. 201
7. Overview of How OSHA Worksp. 205
OSHA Success Storiesp. 206
OSHA's Cooperative Programsp. 206
Voluntary Protection Programsp. 207
Progress and Challenge Aheadp. 207
The Purpose of the OSHA Actp. 208
Citations and Penaltiesp. 212
How Does OSHA Determine Citations Based on the New Rule?p. 218
The Appeals Processp. 227
8. Final Wordsp. 236
Appendix A Regulatory Requirementsp. 243
Appendix B Side-by-Side Comparisonp. 273
Appendix C Fact Sheets from OSHA Websitep. 277
Appendix D Frequently Asked Questionsp. 291
Appendix E Recordkeeping Training Presentationsp. 311
Appendix F Federal Jurisdiction State Plan Statesp. 399
Appendix G Forms for Recording Occupational Injuries and Illnesses and Miscellaneous Informationp. 403
Appendix H OSHA Instructionsp. 433
Appendix I Final Update to OSHA 300 Rulep. 465
Indexp. 469