Q: What does our ministry need to do to follow federal OSHA record-keeping requirements?

Generally, religious organizations are only required to report certain work-related incidents. However, some types of organizations are required to keep more detailed records.

OSHA requires all employers to report all work-related:

• Deaths
• In-patient hospitalizations
• Amputations
• Losses of an eye

For any death that occurs within 30 days of the work-related incident, employers must report the death within eight hours of becoming aware of it. For any in-patient hospitalization, amputation, or eye loss that occurs within 24 hours of a work-related incident, employers must report the event within 24 hours of becoming aware of it. The employer must provide the following information to OSHA:

• The establishment name
• The location of the incident
• The time of the incident
• Type of reportable event (i.e. death, in-patient hospitalization, amputation, or loss of eye)
• The number of employees who were injured in the reportable event
• The names of the employees who were injured in the reportable event
• The contact person and his or her phone number
• A brief description of the incident

According to OSHA’s website, employers can make reports by:

• Calling OSHA's free and confidential number at 1-800-321-OSHA (6742)
• Calling the closest Area Office during normal business hours
• Using the new online form that will soon be available

It’s best to check with a locally licensed attorney to clarify reporting status and whether your ministry is classified as a “low hazard industry” for purposes of OSHA record-keeping requirements. Regardless of classification, all ministries will likely still need to comply with other OSHA requirements.

High-Hazard Industries Require More Detailed Records

Some ministry organizations may be required to keep more detailed records. These requirements apply to organizations that:

• Are not considered to be in a low-hazard industry, and
• Employ more than 10 employees at any point during the calendar year

Also, OSHA, the Bureau of Labor Statistics, or a state agency operating under the authority of OSHA or the Bureau of Labor Statistics may issue a written request for the organization to keep more detailed records.

For organizations that meet this classification, injuries and illnesses must be recorded on OSHA forms if they result in any of the following

• Death
• Days away from work
• Restricted work or transfer to another job
• Medical treatment beyond first aid
• Loss of consciousness
• A significant injury or illness diagnosed by a physician or other licensed health care professional

To record these incidents, use the fillable forms from OSHA’s website.

Consult Legal Counsel

It’s best to check with a locally licensed attorney to clarify reporting status and whether your ministry is classified as a “low hazard industry” for purposes of OSHA record-keeping requirements.

Regardless of classification, all ministries will likely still need to comply with other OSHA requirements—such as providing a safe workplace and following all relevant OSHA safety and health standards. In addition, some states may have their own unique reporting requirements. Consult with a licensed attorney in your area to be sure your ministry is following all applicable laws.

*Important information: Brotherhood Mutual is pleased to provide Legal Assist as a complimentary resource. The services we offer through Legal Assist are intended to provide general legal information to our current and prospective policyholders.

The information we provide is intended to be helpful, but it does not constitute legal advice and is not a substitute for the advice from a licensed attorney in your area. Accordingly, no attorney/client relationship is created through this process, and no legal advice will be provided. We strongly encourage you to regularly consult with a local attorney as part of your risk management program.