Recently, OSHA announced rule making updates to the record keeping requirement for workplace injuries and illnesses. The proposed rule to improve tracking of workplace injury and illnesses was posted Nov 8, 2013; however, the public comment period has been extended to October 14, 2014.

Under the current OSH Act, certain employers are required to keep and submit records of work-related illnesses and injuries (29 CFR 1904.7). The proposed rule adds requirements for the electronic submission of injury and illness information that employers are already expected to keep. The mandatory recordkeeping includes OSHA Forms 300, 300A and 301. Each form contains specific and detailed information about including how long an employer must retain these logs.

Will this update affect OSHA compliance in my practice?

The key is whether you are required to keep OSHA logs or not. Three categories of employers are required to keep OSHA injury and illness records:

  1. Employers under OSHA jurisdiction with 11 or more employees, unless the establishment is classified in a partially-exempt industry.
  2. Employers with ten or fewer employees, if OSHA or the Bureau of Labor Statistics (BLS) informs them in writing that they must keep records.
  3. Establishments in partially-exempt industries, if OSHA or BLS informs them in writing that they must keep records.

But wait, there’s an exception…

Dental offices fall under one of the categories of partially-exempt industries with low worker injury/illness rates from having to complete the recordkeeping. (Appendix A to 29 CFR 1904 Subpart B). Unless OSHA or BLS has informed you in writing you must keep the logs, you don’t need to worry when you see notices about the update later this year.

A good way to enhance your expertise and credentials as well as connect with like-minded professionals is to enroll in our OSHA Compliance for the Dental Professional program where you will learn about this regulation and many other OSHA requirements.

Next week at the AADOM meeting in San Diego, we’ll talk more about this topic when I present Anatomy of a Compliance Audit sponsored by Patterson Dental.  Hope to see you there!

Leave a Comment