General Question - OSHA Reporting
Good Day All,
When asked about their lost work time and WC injury experience, a potential water treatment vendor claims that their NAICS code excludes them from the requirement to track OSHA Recordkeeping 300 log entries. I understand that unoccupied water and wastewater treatment facilities often comply with PSM standards, but does this exclude those companies from the burden of meeting the requirements for tracking injuries and lost time?
If this is true, wouldn't those types of contractors typically be very familiar with JHA's?
Comments (13)
Do you know their NAICS code? There are exemptions from keeping OSHA logs for certain industries. This exemption is mentioned in 1904.2, but the list of exempt industries is found at the link below. Whenever I've come across a company claiming an exemption from this list, I always verify they're using the correct NAICS code since it's a relatively short list.
https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904SubpartBAppA
Wow! I find that hard to believe. Do you know their NACIS code? As you describe their business it is not one I would expect to see on the list in 1904.2.
I am going with Drew! I often wonder how my customers come up with their NACIS codes.
Growing up in bars that my mom and dad managed I wonder about 7224. I sure wonder about that one! My dad got hit in the head by enough beer bottles! I remember at least three times picking him up at the ER for sutures! Heck how did McDonalds get exempted with 7221 or 7222?
We have some of our companies that are exempt from posting requirements due to size but I have been posting the 300A's still due to we share the same facilities with our other companies that are larger and do meet the requirements.
My company falls under NAICS 5241 (Insurance Carriers), so we are exempt from keeping a record. However, 1904 Subpart B states we are exempt "unless [my company is] asked in writing to do so by OSHA, the Bureau of Labor Statistics (BLS), or a state agency operating under the authority of OSHA or the BLS."
Every year, we get a flurry of requests from the BLS. This means we provide reporting per the annual written requirements, but we also chose to save the 300/300A info for a number of years too. We do not post, but retain the info.