OSHA & PERRP Recordkeeping
- DRMA
- Feb 1, 2023
- 3 min read
OSHA and PERRP recordkeeping logs, summary and online reporting are due soon, if you are required to do so. Recordkeeping may seem like a daunting task, but it can be simplified by breaking it down into the following steps:
1) Private employers must determine if they’re exempt from keeping the OSHA Log. All public employers must maintain the PERRP log.
2) Download the Recordkeeping forms and instructions and log all injuries for the calendar year that fall under the criteria of ‘recordable’. Not all injury claims will be recordable.
3) Submit your summary information annually unless your organization is exempt.
Now, let’s take a look at each step in a little more detail.
Exemptions
OSHA - There are two exemptions from keeping the OSHA 300 Log.
· Companies with 10 or fewer employees at all times during the calendar year. The only exception to this is if you are specifically requested by OSHA, the Bureau of Labor Statistics (BLS) or another agency to keep a log. If you receive a request, do not ignore it.
· The other exemption is for establishments classified in certain low-hazard industries. You will need your NAICS number and check it against the list of “Partially Exempt Industries” at: https://www.osha.gov/recordkeeping/presentations/exempttable.
PERRP - There are no exemptions for public employers for keeping and maintaining the PERRP Log. All public employers are required to keep the Log.
*Remember whether you are a private or public employer you must report to OSHA or PERRP, as applicable, any workplace incident that results in a fatality, in-patient hospitalization, amputation or loss of an eye.
Reporting Links
· OSHA REPORTING LINK - Severe Injury Reporting
· PERRP REPORTING LINK – Severe Injury Reporting
Recordkeeping Logs and Summary Forms
OSHA - If you are required to keep the log, download the Recordkeeping Forms and instructions here.
When your PERRP or OSHA log is complete for the 2022 calendar you will need to have the summary form signed and posted in a conspicuous place for employees to see. Summaries must be posted from February 1st through April 30th.
*Remember only post the PERRP 300AP Summary or the OSHA 300A Summary and not the injury log.
Online Submission
The final step in the process is to determine if you must file online.
OSHA - To determine if your organization is required to do so, review the information on OSHA’s Injury Tracking Application (ITA) by going to: https://www.osha.gov/injuryreporting/ and clicking on the “Who is covered by this reporting requirement?” box towards the bottom of the page. If your establishment is required to submit online, then you must create a secure account at: login.gov. Once you have successfully set up an account, then you can submit your OSHA 300A Summary information. The online submission is a fairly straight forward process, just be sure to have your NAICS number, average number of employees and total work hours entered on your OSHA 300A Summary report.
PERRP –All public employers are required to submit to the BWC except those with five or fewer employees and that also have had no recordable injuries in the calendar year. PERRP 300AP Summary form information is submitted through the Ohio BWC link found here: https://www.bwc.ohio.gov/employer/forms/InjuryIllnessSummary/default.aspx.
For more information, please contact Sedgwick’s Andy Sawan at 330.819.4728 or andrew.sawan@sedgwick.com or Craig Lanken at 330.472.1656 or craig.lanken@sedgwick.com
This breakdown of OSHA and PERRP recordkeeping is genuinely useful, especially for someone like me studying occupational health and safety management at university. The distinction between private and public employer obligations was something I had read about briefly in course materials, but seeing it explained this practically made it much clearer.
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