CONN-OSHA Answers Your Safety Questions: September 2022

Welcome to our monthly column featuring CONN-OSHA experts answering some of the most commonly asked safety questions from CBIA member companies.

Most of the responses from Catherine Zinsser, a CONN-OSHA occupational safety training specialist, will be on recordkeeping since that is the focus of most questions she fields.

But if you’d like to ask her a question on another topic, please email CBIA’s Phillip Montgomery.

He will treat all questions confidentially and never share any identifying company information with CONN-OSHA or anyone else.

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Q: We are a general contractor and hire supplemental craft and supervisory employees from a firm that supplies temporary help. One of the employees had a recordable injury. They were directly supervised by our employee.

My understanding of the recordkeeping requirement is that the injury would be entered on our log, not the temporary help company, since we control and direct the employee’s work. Am I correct?

A: Yes. You must record the recordable injuries and illnesses that occur to employees who are not on your payroll if you supervise these employees on a day to day basis.

Day-to-day supervision occurs when in addition to specifying the output, product or result to be accomplished by the person’s work, the employer supervises the details, means, methods and processes by which the work is to be accomplished.

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Q: If I had one work-related accident but two employees were injured, does this get recorded as one or two cases on the OSHA log?

A: OSHA’s recordkeeping system tracks work-related recordable injuries and illnesses.

If both injuries meet the general recording criteria of Section 1904.7 or the application to specific criteria of Section 1904.8 through Section 1904.11, both cases should be recorded on the Log as two separate cases.

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Q: If you have an injury at work and the employer pays for all the cost without turning this into workers compensation do you have to report the accident on the OSHA log?

If the injury meets the OSHA recording criteria, you must record it on the OSHA log regardless of filing for workers compensation.

OSHA’s recordkeeping requirements and the workers compensation system are two independent systems.

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For more information, contact CBIA’s Phillip Montgomery (860.244.1982).