Under the OSHA Injury and Illness Recordkeeping and Reporting Requirements, most employers are required to record work-related injuries and illnesses using the OSHA 300 Logs. However, many businesses, including motorcycle dealerships, are currently exempt from most of the requirements, dependent on the store’s primary Standard Industrial Classification (SIC) code.
All business activities that generate revenue have been assigned a SIC code. The primary SIC code of a business is based on the activity that generates the most revenue. As an example, several different business activities are conducted at a dealership; however, most of the revenue typically comes from the selling of motorcycles, therefore the SIC code for Motorcycle Dealers (5571) is used.
Motorcycle Dealers are exempt from requirements to maintain a log and post a summary of all work related injuries and illnesses. You must verify what SIC code the dealership is using to ensure you are actually exempt. Be aware that OSHA inspectors are often unfamiliar with this exemption. You may need to refer them to 29 CFR 1904.2.
There are several businesses that are associated with the motorcycle industry that are not exempt from the regulation. For example, if offsite facilities are not clearly linked to the sales area of the dealership, the off-site locations may have a different SIC code.
Other examples of non-exempt businesses are:
- Standalone Collision Centers
- Standalone Auto Repair I Qyick lube
- Car Leasing Company
- Truck Centers
- Car Rental Company
- RV Centers
- Parts Warehouses
- Boat and/or ATV Sales & Service
It is important to find out the SIC code being used for each location. This is the only way to determine if you are exempt.
All Facilities Must Comply with OSHA’s Basic Reporting Requirements
All employers regardless of number of employees or the SIC code are required to report fatalities and multiple hospitalizations to OSHA. Also, any facility that is asked by OSHA or the Bureau of Labor Statistics (BLS) to complete an Injury and Illness Survey (usually sent via mail) is required to do so.
Outside of exempt industries, OSHA 300 log usage is quite common. It is widely considered a useful tool for tracking and identifying patterns with workplace illnesses and injuries. Accordingly, some dealerships and dealer groups have elected to maintain OSHA 300 logs, regardless of the exemption, for the benefits provided as a management tool for loss control.