OSHA anticipates that the new record keeping system will be easier for employers to understand, now that instructions for filling out the forms have been clarified and simplified.

Employers who are likely to be covered by this rule should have already received the new forms and instructions in the mail. Homebuilders with 10 or fewer employees are exempt from most of the requirements, as are certain “low hazard” industries such as some retail, finance and real estate.
Highlights of the new record keeping rule include:

• Using new smaller legal sized forms.
• Clarifying how to determine if injuries or illnesses are work-related.
• Using one set of criteria for recording both injuries and illnesses.
• Recording days away from work as calendar days.
• Certifying the accuracy of the records by company executive.
• Protecting the privacy of injured employees.
• Posting the annual summary for three months instead of one.
• Informing employees on the procedures of how to report injuries and illnesses.

   As affected homebuilders change from the old record keeping system to the new one, they should have posted their 2001 summary of injuries and illnesses (OSHA Form 200) by the end of February. Beginning in 2003, the annual summary (OSHA Form 300A) will be required to be posted for three months instead.

In order to assist homebuilders affected by this rule, the National Association of Homebuilders (NAHB) will be conducting a training program at the 2002 International Builder’s Show. Entitled “How to Comply with OSHA’s New Record keeping Requirements,” it will explain how to use the record keeping system to track and record workplace injuries, illnesses and fatalities. A limited number of new forms and instructions will be available at this program.

For additional information, NAHB members can contract Rob Matuga at the group’s Labor, Safety and Health Services offices at (800) 368-5242, ext. 8057, or at rmatug@nahb.com.