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1 Copyright 2006, RSG, Inc. Copyright 2006, RSG, Inc. OSHA Recordkeeping CSU Fitting the Pieces Conference Jeffrey Chung, Jeffrey Chung, PhD CSHM CHFP PhD CSHM CHFP November 7, 2006 November 7, 2006 Paper Pushing or Value Paper Pushing or Value - - Add? Add?
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Page 1: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

1Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

OSHA Recordkeeping

CSU Fitting the Pieces Conference

Jeffrey Chung, Jeffrey Chung, PhD CSHM CHFPPhD CSHM CHFPNovember 7, 2006November 7, 2006

Paper Pushing or ValuePaper Pushing or Value--Add?Add?

Page 2: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

2Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

What You Should “Take Away”

• Overview of Recordkeeping (Regulatory) Requirements

• Recordability Determination Process Steps

• Recordkeeping Mechanics and Forms

• Data Analysis Management Tools

Page 3: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

3Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Background and OverviewBackground and Overview• OSHA views injury and illness records as critical

indicators of employers’ efforts to keep workers safe.

• Injury and illness data pinpoint potential and actual safety management system deficiencies:

4 Hazard identification

4 Hazard control or abatement

4 PPE

4 Safety communication

4 Safety Procedures

4 Safety training

Page 4: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

4Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

California Code of Regulation, Title 8, Section 14300

Source of CA Recordkeeping Requirements

Page 5: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

5Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Organization of CA Recordkeeping Rule

• Purpose - 14300• Scope - 14300.1 & 14300.2• Forms and Recording Criteria - 14300.4 -

14300.29• Other Requirements - 14300.30 - 14300.38• Reporting to the Government - 14300.39 -

14300.42• Transition from the Formal Rule - 14300.43 -

14300.45• Definitions - 14300.46

Page 6: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

6Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300 - Purpose

Requires recording of work-related fatalities, certain injuries and illnesses

Note: Recording work-related fatalities, injuries and illnesses doesn’t mean employer or employee at fault, Cal/OSHA rule violated, or employee eligible for WComp or other benefits.

Page 7: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

7Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Covered Employees

14300.31 -• Injuries and illnesses must be recorded on the

Cal/OSHA Form 300 for all employees:

► on the payroll including those who are

executives, faculty, (salaried or hourly workers)

part-time, grad student, work study

► not on the payroll, but you do supervise on a day-to-day basis must be included:

temporary help services, employee leasing services,personnel supply services, subcontractors

Page 8: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

8Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Employer Expectations

14300.35 -• Employer must:

► set up a system for employees to promptly report work-related injuries and illnesses

► involve employees and their representatives in this recordkeeping system by:

informing each employee about the system for reporting, and telling each employee how to report injuries or illnesses

► provide access as specified to current or stored Cal/OSHA Forms 300, 300A, and 301

for employees, former employees and their personal and authorized representatives

Page 9: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

9Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Employer Expectations

14300.35 - Employers Obligations• Provide copies of current/stored Cal/OSHA 300 or 300A

Forms when requested by employees (current/former) or employee’s personal or union representative:► by the end of the next business day.► without removing names except when "privacy concern"

cases are involved.• Provide copy of the current or stored Cal/OSHA 301

(incident report) Forms when requested employee, former employee, or representative if it describes an injury or illness to that employee:► by the end of the next business day.

Page 10: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

10Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Employer Expectations14300.35 – Employers Obligations• Provide copies of the Cal/OSHA Form 301, Incident

Reports when requested by employee’s union representative (1st set of copies free of charge):► within 7 calendar days.► with certain personally identifying information deleted:

employee name; address; date of birth; date of hire; gender;

physician name; location where treatment was provided;

whether treatment occurred in an emergency room; andwhether employee was hospitalized overnight as an in-patient

Page 11: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

11Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.10 –– Recording Criteria for Cases Involving Occupational Hearing Loss:

• If an employee experienced a recordable hearing loss case, where would the employer record the case on the Cal-OSHA 300 Log?

► If loss is associated with an event, such as acoustic trauma (e.g., an explosion), record as an injury with a check mark in column (M)(1).

► Beginning in January 2004, employers must record all hearing loss cases in separate hearing loss column (m)(5).

Occupational Hearing Loss

Page 12: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

12Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Recordkeeping Penalties/Fines

Cal-OSHA (based on changes from AB 1127 into California Labor Code and Title 8, CCRs) [signed into law 10/99 and effective January 2000 ]:

• Whoever knowingly makes any false statement, representation or certification in any application, record, report, plan or other document filed or required to be maintained, shall upon conviction, be:

• punished by a fine of not more than $10,000, or

• imprisonment for not more than six (6) months,

• or both [14309a]

Page 13: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

13Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Recordkeeping Violations

Per Labor Code Sections 6410 and 6431[14309b], these are Cal-OSHA citable:

• Failure to maintain required records, or

• incomplete details as required,

may result in the issuance of citations and assessment of penalties

Page 14: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

14Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Related Recordkeeping Penalties/Fines

Penalties assessed for failure to abate violations:

4 Up to $7,000/day for failure to correct violations

4 Willful or repeated violations of any Cal-OSHA order may be assessed up to $70,000 for each such violation

4 Anyone cited for making a false statement or certification on records or other documents under Cal-OSHA program is subject to fine of up to $70,000 or imprisonment of up to 6 months, or both.

Page 15: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

15Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Prohibition Against Discrimination

14300.36 -• Section 11(c) of the OSHA Act and Labor Code

Sections 6310 & 6311 prohibit discrimination against an employee for:

► reporting a work-related fatality, injury or illness, or

► filing a safety and health complaint, or

► asking for access to the records, or

► exercising any rights afforded by Section 11(c) or

Labor Code Sections 6310 & 6311

Page 16: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

16Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.4 - 14300.29Recording Criteria

Next . . .

Page 17: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

17Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.4 - Recording Criteria

• Covered employers must record each fatality, injury or illness that is:► work-related, and

► a new case, and

► meets one or more of the general (i.e.,14300.7) or specific (14300.8 - 14300.12) recording criteria

Page 18: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

18Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.4 – 1st Determine Work-RelatednessDid the employee experience an

injury o r illness?

Is the injury or illness a new case?

Is the injury or illness work-re lated?

Does the inju ry or illness meet the general recording crite ria

or the add itional crite ria?

Update the previously recorded inju ry or illness

entry if necessary.

NO

YES

YES

YES

YES

Record the injury o r illness

Do not reco rd the injury o r illness

NO

NO

NO

(2nd Determine Recordability)

Page 19: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

19Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Work-Relatedness Exceptions

14300.5(b)(2) 14300.5(b)(2) --The injury or illness was caused by:The injury or illness was caused by:• the individual:

► voluntarily participating in a wellness program, medical, fitness or recreational activity

► eating, drinking or preparing food or drink for personal consumption

► performing personal tasks (unrelated to their employment) outside assigned working hours

• personal grooming or self medication for non-work-related condition

• an intentionally self-inflicted act

Page 20: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

20Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Work-Relatedness Exceptions (cont’d.)

14300.5(b)(2) 14300.5(b)(2) ––The injury or illness was caused by:The injury or illness was caused by:• a motor vehicle accident in parking lot or access road during

commute• a common cold or flu• Symptoms surface at work that are solely due to non-work-related

event or exposure• The employee was present in the work environment as a member of

the general public• The employee has a mental illness (unless opinion from an Health

Care Provider with appropriate training and experience that mental illness is work related)

Page 21: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

21Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Travel Status and Work-Relatedness

14300.5 (b)(6) –

• An injury or illness that occurs while an employee is on travel status is not work-related if the employee:

► is on a detour for personal reasons which are notwork-related, or

► establishes a temporary residence (e.g. checks into a hotel/motel) and then performs activities which are not in the interest of the employer

Page 22: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

22Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Work at Home

14300.5(b)(7) –• Injuries and illnesses that occur at home are work-

related if they:► happen while work for pay/compensation is being

performed, and ► are directly related to the performance of the job

• Examples :

► puncturing a fingernail during home garment work► dropping a box of work documents resulting in a

foot injury

Page 23: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

23Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.29 -

• Complete Cal/OSHA Forms 300 & 301 or equivalent form within 7 calendar days of receiving information of a recordable case.

► Cal/OSHA Form 300 – Logof Work-Related Injuries and Illnesses

► Cal/OSHA Form 301 –Injury and Illness Incident Report

Forms

Page 24: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

24Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Current Cal-OSHA Form 300

Page 25: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

25Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Cal/OSHA Forms

Page 26: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

26Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Cal/OSHA Forms

Page 27: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

27Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Annual Summary

14300.32 -• Review Cal/OSHA Form 300, then complete Cal/OSHA

Form 300A - Annual Summary of Work-related Injuries

and Illnesses.

• Company executive must certify that he or she has

examined the Cal/OSHA Form 300 and the Cal/OSHA

Form 300A is correct and complete.

• Post summary February 1 - April 30 of the year after

the calendar year the records cover.

Page 28: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

28Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Cal/OSHA Forms

Executive Signature

Page 29: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

29Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Determining Recordability

14300.7 -• An injury or illness is recordable on Cal/OSHA 300 if it

results in one or more of the following: Death

► Days away from work

► Restricted work

► Transfer to another job / Medical surveillance removal

► Medical treatment beyond first aid

► Loss of consciousness

► Significant injury or illness diagnosed by a physician or other licensed health care professional

• 14300.7(b)(2) – Fatalities: mark the column for death

Page 30: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

30Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.7(b)(3) - mark the days away from work column

• enter number of calendar days in the away from work column

• exclude the day of injury or illness

• “cap” the total days away at 180 calendar days

• count the number of calendar days the employee was unable to work regardless of whether or not the employee was scheduled to work on those day(s) [e.g., weekends, holidays, vacation days, etc.]

Days Away

Page 31: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

31Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.7(b)(3) 14300.7(b)(3) --• If a case occurs in one year but results in days away

during the next calendar year, record the injury or illness once: ► count the number of calendar days away for the year

when the injury or illness occurred ► for the annual summary, if the employee is still away,

estimate the total number of calendar days you expect the employee to be away

use this number to calculate the total for the annual summary.update the initial log entry later when the day count is known or reaches the 180-day cap.

Days Away Cases

Page 32: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

32Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.7(b)(4) –(Under the Remained at work column mark job transfer or restricted workdays)

• Restricted work:► occurs when the employer, a physician or other

licensed health care professional keeps the employee from performing:

one or more routine job functions (i.e. work activities regularly performed at least once per week), or working a full workday

► count just like days away from work

Restricted Work

Page 33: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

33Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.7(b)(4) -• do not count restriction if limited only to day of the

injury or illness

• count each partial day of work as a day of restriction except the day when the injury or illness began

• production of fewer goods or services is not considered restricted work activity if employee can perform all the routine functions of the job

Restricted Work

Page 34: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

34Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.7(b)(4) –• means injured or ill employee is assigned to a job

other than regular job for at least a part of any work day

► under Remained at work, mark job transfer or restricted workdays column

► count just like days away from work

► do not count the day the injury or illness occurred

► count at least one day

Job Transfer

Page 35: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

35Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.7(b)(5) – must be recorded:

• even if employee does not follow medical treatment recommended by a physician or other licensed health care professional.

• It does not include: not to be recorded if:

► visits to licensed health care professional solely for

observation or counseling.

► diagnostic procedures (x-rays, blood tests, prescription

medications used solely for diagnostic purposes).

► first aid (as defined in the regulation).

Medical Treatment Beyond First Aid

Page 36: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

36Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.7(b)(5) -• First aid means using:

► nonprescription medication at nonprescription strength► wound coverings, gauze pads, butterfly bandages,

Steri-Strips

► hot or cold therapy

► non-rigid means of support ► temporary immobilization devices while transporting an

accident victim

► eye patches► finger guards

First Aid Are Non-Recordable Cases

Page 37: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

37Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

First Aid Are Non-Recordable Cases14300.7(b)(5) -► massages

► Removing

foreign bodies from eye using irrigation or cotton swab

splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means

► Administering Tetanus immunizations► Cleaning, flushing, or soaking surface wounds

► Drilling of fingernail or toenail, draining fluid from blister► Drinking fluids for heat stress

Page 38: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

38Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.7(b)(6) -• Must be recorded regardless

of the length of time the employee remains unconscious

► classify by marking column (G - J) which represents the most serious outcome of the loss of consciousness

Loss of Consciousness

Page 39: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

39Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.7(b)(7) –• Includes (but is not limited to) cancer, chronic

irreversible diseases (e.g. asbestosis, silicosis), fractured or cracked bones, punctured eardrums. Record:► only once at the time of diagnosis by a physician or

other licensed health care professional ► by marking Other recordable cases column (i.e.

column J), if the significant diagnosed injury or illness did not results in:

death, ordays away from work ora job transfer or restriction

Significant Diagnosed Injury or Illness

Page 40: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

40Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.8 -• Record exposures to blood or Other Potentially

Infectious Material (OPIM) as:► injuries if needle sticks or cuts from sharps are

involved► illnesses if a splash or other exposures result in a

diagnosis of a blood borne illness (e.g. HIV, hepatitis B, or hepatitis C)

► medical treatment beyond first aid. (e.g. HIV post-exposure prophylaxis treatment, hepatitis B immune globulin, gamma globulin, hepatitis B vaccination).

Recording Criteria – Needlesticks/Sharps Injuries

Page 41: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

41Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.8 -• Other Potentially Infected Material (OPIM) includes

the following materials:► Human bodily fluids, tissues and organs, and► Other materials infected with the HIV, hepatitis B

virus (HBV) or hepatitis C virus (HCV) such as laboratory cultures or tissues from experimentalanimals.

• To protect privacy, do not enter the employee's name on the Cal/OSHA Form 300

Recording Criteria – Needlesticks/Sharps Injuries

Page 42: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

42Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.8 -• If cuts, lacerations, punctures or scratches are work-

related and do notdo not involve contamination with another persons blood or OPIM, record only if incident involved:► Death► Days away from work► Restricted work ► Transfer to another job► Medical treatment beyond first aid► Loss of consciousness► Significant injury or illness diagnosed by a physician or

other licensed health care professional

Recording Criteria – Needlesticks/Sharps Injuries

Page 43: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

43Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.8 -• If a recorded injury is later

diagnosed as an infectious bloodborne disease causing death, days away from work, restricted work, or job transfer:► update the description to

identify the disease

► change the classification from an injury to an illness

Recording Criteria – Needlesticks/Sharps Injuries

Page 44: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

44Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Occupational Hearing Loss Recordability

14300.10 - Definitions

• Standard Threshold Shift (STS) – change in the average level at which various frequencies of sound can be heard relative to a baseline audiogram.

• Work-related Hearing Loss – an event or exposure in the work environment either caused or contributed to the hearing loss or significantly aggravated a pre-existing hearing loss.

Page 45: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

45Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.10 –Employers must record if employee’s current audiogram reveals:

• work-related Standard Threshold Shift (STS) of 25 decibels or more (averaged at 2000, 3000 and 4000 hertz) above audiometric zero in the same ear.

• no age adjustment.

• determine if case is work – related using T8CCR 14300.5

• check Other Illnesses on Cal/OSHA form 300 (or equivalent).

Occupational Hearing Loss

Page 46: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

46Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.10 - Retesting

• Must retest within 30 days of test revealing recordable STS.

• If retest:► Confirms recordable STS, record within 7 calendar

days of retest► Does not confirm recordable STS, do not record case

• If further testing under T8CCR 5097 reveals recordable STS has not persisted, erase or line-out entry on Log 300 .

Occupational Hearing Loss

Page 47: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

47Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.11 -• Record when the employee :

► is occupationally exposed to a known case of active (TB), and

► subsequently develops a tuberculosis infection, as evidenced by a

positive skin test, or diagnosis by a physician or other licensed health care professional

• Record by marking the “respiratory condition” column

Work-related Tuberculosis (TB) Cases

Page 48: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

48Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Work-Related Tuberculosis (TB) Cases

14300.11 14300.11 --• A recorded TB case may be removed from Cal/OSHA

Form 300 when it was not caused by occupational exposure, as evidenced by : ► a positive TB skin test resulting from a pre-employment

physical ► the employee living in a household with a person

diagnosed with active TB► the Public Health Department identifying the employee as a

contact of an individual with active TB, unrelated to the workplace

► a medical investigation showing the infection was caused by exposure away from work

Page 49: OSHA Recordkeeping - California State University · OSHA Recordkeeping CSU Fitting the ... Cal-OSHA 300 Log? ... Recordkeeping Penalties/Fines Cal-OSHA (based on changes from AB 1127

49Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.12 14300.12 --• Employers are required, until December 31, 2003, to

record work-related injuries or illnesses involving:• muscles, nerves, tendons, ligaments • joints, cartilage, spinal discs

(Note: use the same general requirements for any injury or illness)

• For entry "M" on the Cal/OSHA 300, mark either:• injury, or • all other illnesses

Work-Related Musculoskeletal Disorders

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50Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

“Privacy Concern Cases”

14300.29 - Forms

• Keep a separate confidential list of the case

numbers and employee names for “privacy

concern cases” so they can be:

► updated when appropriate, and

► provided when required

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51Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

14300.29 - Forms• Do not enter the name of an employee on the

OSHA Form 300 for “Privacy concern cases:

—Write “Privacy case” in the name column

—You must keep a separate, confidential list of the case numbers and employee names for your privacy concern cases so you can update the cases and provide the information to the government if asked to do so.

“Privacy Concern Cases”

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52Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

“List of Privacy Concern Cases”

14300.29 - Forms• The complete list of “Privacy Concern Cases”:

► injuries or illnesses to intimate body parts or the reproductive system

► mental illnesses

► HIV infection, hepatitis or tuberculosis

► injuries or illness resulting from sexual assault

► Need stick injures and cuts from sharp objects contaminated with another person’s blood or OPIM

► Other illnesses where the employee independently and voluntarily request their name not to be entered on the log

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53Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

“Privacy Concern Cases”14300.29 - Forms• Use discretion in describing the injury or illness on

Cal/OSHA Form s 300 & 301 if:—the employee’s name was removed from the forms, and —a reasonable basis exists to believe that the individual could

still be identified

• Remove or hide employee names when Cal/OSHA Forms 300 or 301 are voluntarily disclosed to persons other than:

— government representatives — employees — former employees — authorized representatives

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54Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

“Privacy Concern Cases”

14300.29 - Forms• Voluntarily disclose Cal/OSHA Forms 300 or 301

with personally identifying informationwith personally identifying information only to:

► auditors or consultants hired by the employer to evaluate the safety and health program

► the extent necessary for processing workers’ compensation or other insurance claims

► public health authorities or law enforcement agencies

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55Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Retention and Updating

14300.33 -• Retain the following forms for 5 years, after the year the

forms cover:► Cal/OSHA Form 300, Cal/OSHA Form 300A, ► Cal/OSHA Form 301, Incident Reports, Privacy Case List

• Update Cal/OSHA Form 300 during retention period if:► newly discovered recordable injuries or illnesses arise ► any changes occur in the classification of previously

recorded injuries and illnesses, or► changes occur in the description or outcome of a case

• You do not need to update the Cal/OSHA Form 300A or Cal/OSHA Form 301during the retention period.

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56Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Using Indicators/Metrics to Drive:• Injury Prevention• Cost Containment• Continuous Quality Improvement (CQI)• World Class Performance

PERFORMANCE MEASUREMENT

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Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Incidence Rate Formulas1) Total Recordable Incidence Rate (TRI) =

Number of injuries & illnesses X 200,000

Total hours worked by all employees in period• Unit of Measurement: number of injuries and

illnesses occurring every 200,000 hours worked.

• Use actual total hours worked in a year; if not available, estimate total hours worked in a year by multiplying 2,000 for each full time equivalent employee (FTE).

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Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Incidence Rate Formulas2) Lost Workday Case Rate (LWC) =

Number of lost workday cases X 200,000

Total hours worked by all employees in period

• Unit of Measurement: number of lost work day cases occurring every 200,000 hours worked

• Use actual total hours worked in a year or estimate total hours worked in a year by multiplying 2,000 for each full time employee.

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Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Incidence Rate Formulas3) Severity Rate =

Number of lost work days X 200,000

Total hours worked by all employees in period

• Unit of Measurement: number of lost work days

occurring every 200,000 hours worked

• Use actual total hours worked in a year or estimate

total hours worked in a year by multiplying 2,000 for

each full time employee.

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Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Incidence Rate Formulas

4) Average Lost Work Days per LWD Case =

Total lost work days

Total cases involving days away from work

• Unit of Measurement: number of lost work

days typically occurring for each LWD case.

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Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Control Charts for Data Variability• Control Charts evaluate significance of I/I changes. • Control chart distinguish random variation from caused

variation [at 95% confidence level].• Determine average number injury/illness cases per

month (n) over a 60 months’ experience (# cases/60 mos.).

• Establish upper control limit (UCL) and lower control limit (LCL):

4 UCL = n + 2 n4 LCL = n - 2 n

• Any I/I changes within UCL/LCL bands are random and not statistically significant; changes falling outside bands are statistically significant.

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Copyright 2006, RSG, Inc.Copyright 2006, RSG, Inc.

Control Chart IllustrationIn

jurie

s P

er M

onth

15

25

35Upper Control Limit

Lower Control Limit

Average

J F M A M J J A S O N DMonths

Upper and lower limits of this control chart were based on 60 months’ experience, and shows points at which the number of injuries and illnesses can statistically be shown to have a contributing cause rather than by chance. Thus actin can be taken where it will be most effective.


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