June 2003

Safe Sense
Workplace Tips

OSHA Record-Keeping
Keeping Track of First-Aid Kits and First-Aid Treatment
by Bill Carson

During my travels and inspections, I have found that most companies do not have what I would call an Occupational Safety and Health Administration (OSHA)-approved first-aid kit, nor are they replenished when supplies are low.

I was at one company that employed 200 workers and had only one first-aid kit (with limited supplies) in the front office. It’s also common to find plenty of gauze and no Band-Aids or other basic supplies. In fact, most employees just come in and help themselves when there is a need. This will offer you little comfort if and when you actually need the kit in an emergency.

What You Need
First-aid kits are simple to purchase today and very inexpensive when you compare them to other company purchases. Your first-aid kit should include a pair of surgical-type rubber gloves that can be used to assist someone who is bleeding in an attempt to prevent HIV or other illnesses transferred by blood. This sounds logical now, but if an employee was injured and was bleeding profusely, I don’t think we would take the time to find a pair of rubber gloves, though we should.

Under 29 CFR 1926.50, first-aid supplies are required to be easily accessible in the shop. Each company needs to assess the needs for first-aid supplies based on their workplace 

For those companies that have trucks on the road, Department of Transportation (DOT) regulations require a first-aid kit and fire extinguisher on each truck. Delivery trucks and service trucks come under the DOT regulations—not OSHA. Also, remember that a fire extinguisher is required every 75 feet within your shop, yard, etc., and must be maintained and checked annually.

First-aid treatment is another issue by itself. Under 29CFR 1904.7, first-aid treatment that can be provided by an employer includes:

• Using a non-prescription medication at non-prescription strength, such as lotions, ointments, etc.;

• Cleaning, flushing or soaking wounds on the surface of the skin;

• Using wound coverings, such as Band-Aids, gauze, etc.;

• Using hot or cold therapy;

• Using temporary immobilization devices (splints) while transporting a victim;

• Using eye patches;

• Removing foreign bodies from the eye using only irrigation or a cotton swab; and

• Providing fluids for heat stress.

First-aid treatment does not need to be recorded, but any treatment by a licensed practitioner should be.

What OSHA Requires
OSHA record-keeping forms are required for all companies that employ at least ten persons anytime during a calendar year. If you have less than ten employees, you are not required to maintain records, but you are still liable under the OSHA standards.

All employee deaths, injuries or illnesses that result in absences, require medical treatment beyond first aid, result in transfer to another position or in which an employee becomes unconscious must be recorded. Also, any injury or illness diagnosed by a physician or other licensed health care professional must be recorded, even if it does not meet the aforementioned criteria.

All injuries or illnesses that meet the criteria in the above paragraph must be recorded on the OSHA 300 form, which is a log of occupational injuries and illnesses. If a death occurs, OSHA must be notified within eight hours. The OSHA 300 form provides a space for a basic description of what happened. Remember that the OSHA 300 form must be posted where employees can see it during the month of February, listing all injuries or illnesses that occurred during the past calendar year.

The problem with record-keeping in most small companies is determining who is responsible for maintaining the records, especially when there are no administrative employees.

The answer to that question is easy: the boss, owner or the person in charge. Someone has to be responsible. Your workers’ compensation carrier should be able to provide you with OSHA record-keeping forms, or visit to order any forms you might need. 

Bill Carson is manager of ManCon LLC of Lake Mary, Fla. He has spent more than 15 years developing, managing and supervising training programs for the building-products industry. As a free service to SHELTER readers, Mr. Carson is available for your safety questions at 407/330-1698.


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