Construction Recordkeeping Compliance

Training in the construction industry is a LEADING INDICATOR AND PREVENTION OF INJURY AND DEATH IN THE WORKPLACE. Not only is proper training good practice, it is also one of OHSA’s most common citations. Proper training and the documentation of that training can save thousands of dollars in fees, lost time and insurance claims.
OSHA requires recordkeeping in two areas; Injuries & Illnesses and Safety Training.
 
Injury & Illness Reporting Requirements
OSHA requires construction employers with 10 and more employees to keep a record of serious work-related injuries and illnesses.

What is considered a recordable injury?

• Any work-related fatality
• Any work-related severe injury
• Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job
• Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums
• There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis
• Any work-related injury or illness requiring medical treatment beyond first aid

 
What is considered First Aid?

• Using a non-prescription medication at non-prescription strength
• Administering tetanus immunizations
• Cleaning, flushing or soaking wounds on the surface of the skin
• Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.
• Using hot or cold therapy
• Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. that does not immobilize the injured area
• Using temporary immobilization devices while transporting an accident victim
• Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister
• Using eye patches
• Removing foreign bodies from the eye using only irrigation or a cotton swab
• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
• Using finger guards
• Using massages
• Drinking fluids for relief of heat stress

 
What does OSHA consider a severe injury?
A severe injury includes a fatality, amputation, loss of eye, or hospitalization (formal admission to hospital for treatment). In the case of a fatality, OSHA must be notified within (8) hours of the incident. In the cases of amputation, loss of eye, or hospitalization, OSHA must be notified within (24) hours of the incident.
 
How do you record these injuries and illnesses?

• OSHA 300 Form – Log of Work-Related Injuries & Illnesses
• OSHA 300A Form – Summary of Work-Related Injuries & Illnesses
• OSHA 301 Form – Injury & Illness Incident Report

Construction is considered a high hazard industry by OSHA therefore companies with 10 or more employees are required to maintain the forms listed above. The OSHA 300, 300A and 301 forms must be updated each year and posted by location. OSHA requires these forms to be kept for a minimum of (5) years after their expiration.

​*A recent update (2/25/2019) now does not require companies with more than 250 employees to electronically submit their OSHA 300/301 forms. They are still required to maintain these records each year and continue posting by location.
 

​Training Reporting Requirements (29 CFR 1910/1926)
It is the employer’s responsibility to initiate and maintain programs for accident prevention.
Training is both task and hazard specific. Below is an example of when training is required:

• Prior to beginning work (orientation) to recognize unsafe conditions, hazards, and potential injuries/illnesses
• Prior to operating machinery
• Prior to handling hazardous materials and/or flammable liquids
• Working within a confined space

​How often in training required?
OSHA requires that some trainings be repeated after a certain period of time. Below are several of those trainings. 

Training Name	Renewal Period
Bloodborne Pathogens	Every Year
Confined Space	Every Year
Hazardous Waste	​Every Year
Occupational Noise	​Every Year
Respiratory Protection	Every Year

Training Name	Renewal Period
First Aid	Every 2 Years
Process Safety Management	Every 3 Years
Powered Industrial Trucks	Every 3 Years
Aerial Lift	Every 4 Years

Here is a complete list of Training Standards
 
When are refresher trainings required?
Refresher trainings are required to reiterate the most important aspects of a training and also to incorporate any changes made pertaining to the specific topic. Refresher trainings should be implemented when one of the following instances occur:

• Post-Accident or Injury
• When an employee is observed using equipment improperly
• Upon failing an annual equipment evaluation
• When new equipment is implemented
• When workplace conditions change

Companies can also provide their own refresher requirements as long as they meet or exceed OSHA standards.
 
What kind of information should be recorded for training?
Training documentation should include:

• Name/Signature of trainer
• Trainee Name
• Date of training
• Subject of training
• Proof of competency (written exam or practical evaluation)
• Date of evaluation

OSHA requires these documents be available to employees upon request.
 
The best ways to keep your employees safe in the workplace is to provide them with the proper tools and training to get the job done correctly without putting them in danger. STAC emphasizes this by assisting in recording injuries & illnesses and tracking your employee safety trainings and certifications. By having real-time access to these important records, you can have the peace of mind knowing your employees have been given the proper training that is up to date with current standards.
 
Additional Resources:
PART 1904 - RECORDING AND REPORTING OCCUPATIONAL INJURIES AND ILLNESSES
PART 1926 - SAFETY AND HEALTH REGULATIONS FOR CONSTRUCTION
Training Requirements in OSHA Standards