Sheet Metal & Air Conditioning Contractors’ National Association


OSHA Recordkeeping Requirements – Posting Requirements

Dec 12, 2012

OSHA Recordkeeping Requirements – Posting Requirements

One program that is part of every OSHA inspection is recordkeeping including injury and illness data most SMACNA firms should be collecting. The summary of 2012 records needs to be posted and available for employee review from February 1 through April 30, 2013 using the OSHA Form 300-A. State’s with State OSHA Programs (i.e., CA, OR, MI, etc.) have a similar form.

As a reminder, the requirements for recording an injury or illness can be complicated and companies should avoid “over-reporting” of injuries that could lead to an over-inflated OSHA injury incidence rate. Injuries should be recorded if they require medical treatment beyond first aid. For example, if an employee cuts a finger and receives “first aid” only (Band-Aid or bandage), then that injury is most likely NOT recordable. However, if the cut requires stitches (considered medical treatment), then it is recordable.

Also, “recording” an injury is different than “reporting” an injury. According to OSHA, you need to record injuries and illnesses in compliance with the Recordkeeping guidelines. However, you need to report to OSHA any fatality or in-patient hospitalization (hospital admitted) of three or more workers within eight (8) hours by contacting the nearest OSHA office or the “800” phone number on the OSHA website. Note: the requirement of three or more workers may be revised for 2013 to include any in-patient hospitalization.

SMACNA members needing information on OSHA’s recordkeeping requirements are encouraged to use the free SMACNA Recordkeeping On-Line Course available in the safety and health section of the SMACNA website.

If you have questions about OSHA requirements, go to the OSHA recordkeeping website or contact Mike McCullion, Director of Safety and Health by telephone at (703) 995-4027 or by e-mail at (