OSHA Inspections and Recordkeeping

OSHA inspection priorities: (1) Imminent danger, (2) Fatalities/catastrophes, (3) Worker complaints, (4) Referrals, (5) Programmed inspections. Report work-related fatalities within 8 hours. Report hospitalizations, amputations, or eye losses within 24 hours. Inspection phases: opening conference, walkaround inspection, closing conference. Workers have walkaround rights (Section 8(e)) to accompany the inspector. Employers may require OSHA to obtain a warrant before entry, though this is uncommon.

Recordkeeping: Form 300 (log maintained throughout the year), Form 300A (annual summary, post Feb 1–Apr 30), Form 301 (individual incident report, complete within 7 days). Recordable cases: days away from work, restricted work/transfer, medical treatment beyond first aid, loss of consciousness, significant diagnosis. First aid is NOT recordable. Partial exemptions for employers with 10 or fewer employees and low-hazard industries. Records retained 5 years. Electronic submission required for establishments with 250+ employees or 20-249 employees in specified industries.

For OSHA 30 supervisors: the supervisor plays a critical role in recordkeeping accuracy. Supervisors must ensure all injuries and illnesses are reported promptly — workers should be encouraged to report without fear. Incident investigations (not just for recordability but for root cause analysis) must be completed promptly. Supervisors should understand the difference between a recordable and non-recordable case, how to complete a Form 301, and how to avoid common recordkeeping errors. Never discourage injury reporting — doing so is a violation and undermines the safety program.