Digital Recordkeeping and Stair Design Just Got Clearer (And More Critical)

Staying ahead of regulatory changes and interpretations is a constant challenge for safety professionals. Recently, OSHA announced the release of Letters of Interpretation that impact how we manage injury/illness records and design/inspect walking-working surfaces. Two of these interpretations are particularly noteworthy for ASSP members, providing both clarity and a call to action.

Let’s break down what you need to know:

1. Digital Recordkeeping: Yes, Your Software Can Be Compliant (But Check the Fine Print!)

Many organizations today leverage sophisticated software to manage their safety data, including injury and illness records. OSHA has clarified that it will accept documents generated by your company's software as a substitute for the official OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and Form 300A (Summary of Work-Related Injuries and Illnesses).

This is a significant acknowledgment of modern recordkeeping practices, but it comes with a critical caveat: Your software-generated forms MUST meet all the requirements for "equivalent forms" as detailed in 29 CFR 1904.29 and 29 CFR 1904.32.

What does this mean for you?

If you're using a third-party EHS software solution, an internal database, or even a custom spreadsheet to track incidents, it’s imperative to:

• Audit Your Output: Compare your software’s generated forms against the specific data fields required by OSHA Forms 300 and 300A. Ensure no critical information is missing, such as the date of injury, location, extent/outcome of the injury, employee name, job title, and the number of days away from work or on job transfer/restriction.
• Understand "Equivalent": The term "equivalent" means providing the same information in a clear, comprehensible, and accurate manner, readily accessible for review.
• Avoid Assumption: Don't assume your software is automatically compliant. Proactive verification is key to avoiding potential citations during an OSHA inspection.

This interpretation offers flexibility but places the onus squarely on employers to ensure their digital recordkeeping solutions are genuinely equivalent to OSHA's prescribed forms.

2. Stair Design: OSHA Solidifies Tread Depth Measurement, Aligning with ANSI A1264.1

For those involved in facility design, construction, or inspections, this next interpretation provides crucial clarity on fixed industrial stair requirements, specifically regarding tread depth. OSHA recently reinforced its stance on the minimum 9.5-inch tread depth for standard stairs (as per 29 CFR 1910.25(c)(3)).

The core of the interpretation focuses on how that tread depth is measured:

• The Correct Method: Tread depth must be measured horizontally between the vertical planes of the foremost projection of adjacent treads. Crucially, any beveled or rounded tread surfaces that slope more than 20 degrees should be excluded from this measurement.
• The Non-Compliant Example: OSHA cited an example of stairs with an angle between 49-50 degrees and a nominal 9.5-inch tread, but with an 8-inch run and a 1.5-inch nosing. These were deemed non-compliant because the actual usable tread depth for stepping was less than the required minimum.

Why this matters and where ASSP comes in:

Perhaps the most significant aspect of this interpretation for our members is OSHA's explicit statement that its intention for the 9.5-inch minimum tread depth is "consistent with national consensus standards for standard stairs (ANSI A1264.1 and NFPA 101)."

This is a direct validation of the ANSI A1264.1 standard, which ASSP develops and champions.

• Reinforced Authority: This interpretation solidifies the ANSI/ASSP ANSI A1264.1 Standard (Safety Requirements for Workplace Walking/Working Surfaces and Their Access) as an authoritative guide for compliant stair design and inspection.
• Practical Application: Use this interpretation to confirm your facility's stairs meet the stringent measurement criteria. It's a reminder that minor design nuances, like the true horizontal measurement of tread depth, have major safety implications.
• ASSP Resources: If you're designing new stairs, modifying existing ones, or conducting safety audits, referencing the ANSI/ASSP A1264.1 Standard is more critical than ever. ASSP provides resources, training, and access to this vital standard to ensure our members are equipped with the most up-to-date and compliant information.

Key Takeaways for ASSP Members:

These OSHA interpretations provide valuable guidance but also underscore the need for vigilance.

1. Review Your Recordkeeping Software: Don't wait for an inspection. Proactively ensure your digital forms meet all OSHA equivalency requirements.
2. Affirm Stair Design Principles: Apply the clarified tread depth measurement method and lean on ANSI A1264.1 as your go-to resource for compliant walking-working surfaces.