OSHA Recordkeeping for Occupational Injuries and Illnesses

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OSHA 2002 Recordkeeping Safety Training Workshop

OSHA Recordkeeping for Occupational Injuries

and Illnesses … a Practical Overview and Application of the

New Revised Standard

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Do...

Ask a question when you have one Feel free to share an illustration Request an example if... Search for ways to apply principles or

ideas Think of ways to pass information on

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Don’t...

Try to develop a problem to the extreme Close your mind by saying this is all fine

in theory, but... Assume that all topics covered are equally

relevant to your needs

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History of the Regulations> Original regulations completed 1971> Proposed changes announced in 2/96

(“The Revision of the Injury & Illness Recordkeeping System”)

> Revision announced 1/18/01> Final rule in CFR 1/19/01> Revisions and clarifications 7/3/01 [FR Notice]> Final rule effective 1/1/02

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To record/ report occupational fatalities, injuries, & illnesses.

Aid employers with recognizing workplace hazards & correcting hazardous conditions

Allow OSHA to track safety trends— Does not indicate fault,

— Or OSHA violated standard,

— Or injury is WC compensable

Purpose and Intent of the Standard

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Why Were New Regulations Necessary?

Process simplification New issues to track Current form complex, difficult to understand Current guidelines too long Too many interpretations Reflect more accuracy with lost time

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Occupational Injuries & Illnesses

OSHA 2001 Revision within 29 CFR 1904 outlines employers’ responsibilities for recording and reporting work-related injuries and illnesses

Exemptions (determined by SIC code)

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Who is Exempt from New Rules? Employers < 10 employees at all times during the year. Certain low hazard retail, service, financial, insurance,

or real estate SICs. (See List)— http://www.osha-slc.gov/recordkeeping/RKbrochure.html

If injury records already maintained for another federal agency, (e.g., MSHA)

Self employed businesses

NOTE- Temporary Staffing - If you supervise day to day, cases go on your log!

— Determine in your contractDetermine in your contract

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Employer/Employee Relationship

Who provides day-to day-supervision? Who specifies output, product, or result to

be accomplished? Who supervises details, means, methods,

and processes by which work is accomplished?

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What Information is to be Recorded?

Within 7 days, each fatality, injury or illness that:— Is work related and,— Is a new case and, — Meets one or more of the recording criteria.

• DEATH or MULTIPLE (3 or more) HOSPITALIZATIONS – (report to OSHA within 8 hours)

• DAYS AWAY FROM WORK• RESTRICTED WORK OR TRANSFER• MEDICAL TREATMENT BEYOND FIRST AID• LOSS OF CONSCIOUSNESS• ILLNESS or INJURY DIAGNOSED BY A PHYSICIAN

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Recording Criteria Covered employers to record fatality,

injuries or illnesses as defined..— Must be work related, or— A “new” case, or— Meets 1904.7 - .12 criteria

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Recording Criteria (Decision Tree)Did the employee experience an injury or

illness?

Is the injury or illness work related?

Is the injury or illness a new case?

Does the injury or illness meet the general recording criteria or the application to specific cases?

YES

YES

YES

NO

NO

NO

Do not record the Injury or illness

Update the previously recorded injury or illness entry if necessary

YES

Record the injury or illness

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What Records Must Be Kept? Injury & Illness Log (300) & Summary (300A) Form 301 (unless state form has same criteria) Form 300A must be posted (except for employee name) 2/1-

4/30 Both forms (300/300A) must must be signed by responsible

company official• Accountable for certifying accuracy and

completeness of the Log & Summary• Owner, officer, highest ranking company official or immediate supervisor of

highest ranking official of company

All columns year end totals (includes zeros)

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The 300A Form This form must be posted each February 1- April 30 Update as needed for 5 years, following the end of the

year to which they relate Changes reporting of fatalities and catastrophes to

exclude some motor carrier and motor vehicle incidents

OSHA allows all recordkeeping forms and summaries to be kept on computer equipment or at alternate location

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Form 300A Summary Information

# Cases — [Deaths, LWD’s, Job transfer/ restriction, other recordables

and medical incidents] # Days

— Job transfer or restriction, # days away from work # Injuries/ Illnesses by Types [Columns M 1-7]

Establishment Information— Name and address— Industry description and SIC code— Employment information

• Annual average # of employees & total hours worked by all employees

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OSHA Form 301

Injury and Illness Incident Record— Required for each entry on log— Other forms (WC, insurance) may be

substituted if they contain similar information— Must be completed within seven (7) days of

employer receiving notice of the injury or illness

— Must be kept for five (5) years following end of calendar year

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Updating to Stay Current During retention period, employers must revise form

300 to include newly discovered information or changes to previously recorded injuries and illnesses

If description or outcome changes, remove original entry and enter new data— Avoid “white out or erasing entries… line out

Employers must revise form 300 at least quarterly if changes have occurred

Retain for 5 years following covered year

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Determining Work Relatedness

If event/ exposure [in the work environment]— caused or contributed to the resulting condition or— significantly aggravated a pre-existing injury or illness.

Work Environment is defined as... — “the establishment [and other locations] where one or

more employees are working or are present as a condition of employment. Includes the equipment or materials used by the employee in the course of his or her work.”

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What is “Significantly Aggravated”?

A pre-existing injury or illness is Significantly aggravated if it results in — DEATH— LOSS OF CONSCIOUSNESS— ONE OR MORE DAYS AWAY FORM WORK— MEDICAL TREATMENT

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Determining Work Relatedness; Company Ball Fields

Company recreational facilities are not considered part of the employer’s premises. The presumption of work relationship for these activities does not apply, unless the employer has required their use.

However, employees engaged in work-related activities at these locations are covered— Attendants or specialists working at the recreational

facility employed by that facility

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Company Parking Lots

Company parking lots are considered part of the employer’s premises; hence, injuries on these lots are presumed to be work related.

Employees engaged in work-related activities on parking lots (such as resurfacing commencing on a business trip, etc.) are covered.

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Travel Status Coverage includes only those activities necessary for

the business trip. — Normal living activities are excluded — Not related when on a “personal Detour”

Hotel as a “home away from home” — Left work environment when checked in— Employee is considered “on the clock” until reaching their

“home away from home”

Detour, for personal reasons, is not work related

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An injury or illness is work related if it occurs while the employee is performing work for pay at the home AND it is directly related to performance of the work rather than to the general home environment or setting.

Determining Work Relatedness: Telecommuting from Home

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No previously recorded injury or illness of the same type and part of body, OR...

A previously recorded injury or illness of the same type/body part, but recovered* completely and a “new” workplace event caused them to reappear.

*(all signs/ symptoms had disappeared)

What is a “New” Injury or Case?

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What is “First Aid”?

One-time treatment (+ follow-up observation) of minor scratches, cuts, burns, splinters, etc., which don’t require medical care

OSHA does not require recordkeeping for first aid treatments as defined in the standard

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What is Considered 1st Aid?

Treatments [A-N] are considered First Aid, even if administered by a physician/ HCP...

— A) use of a non prescription medication— B) Tetanus immunizations— C) Cleaning, flushing or soaking wounds on the skin— D) Using wound coverings I.E.....— E) Hot or Cold Therapy— F) Non rigid support (ace bandages)— G) Temporary immobilization devises

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What is 1st Aid? (cont.)

— H) Drilling of a finger / toe nail to relieve pressure— I) Eye Patches— J) Irrigating FO from eye with water or cotton— K) Removing splinters by irrigation tweezers cotton etc— L) Using finger guards— M) Using massages— N) Drinking fluids for heat stress

Most other remedies are considered “medical” treatment and must be recorded!

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Needle Sticks/ Sharps Incident Recording

Record all which might have Bloodborne pathogen potential as an injury case

Must use the privacy provision If splashed with blood but not cut, record

as an illness case

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Site Controlling Employer

SIC codes 15, 16, 17 must have a Site Controlling Employer (SCE)— Employer with control over performance,

timing, or coordination of work— Initial total contract value $1,000,000+— Employer retaining another employer (general

contractor) — Employer with managerial or supervisory

authority (manager)

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Required to keep a separate OSHA 300 form for each establishment expected in operation over 1 year

May keep one OSHA 300 form for all establishments (short term duration)

Each worker must be linked with an establishment.

Site Controlling Employer/ SCE (continued)

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Site Controlling Employer/ SCE (continued)

SCE:— Must keep subcontractor records— Must keep separate records for subcontractor

employees if there are 11 or more

Employer of subcontractor employee:— Must complete OSHA Form 301— Must prepare year-end summary— Must update injury/illness records

Most often, however, subcontractors will be responsible for their own records as long as they fall under the criteria listed within the scope of this standard

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Recording a “Fatality”

Check the box in the column for “Deaths” (G) — Report to OSHA within 8 hours of incident

• If OSHA office is closed, call 800- 321-OSHA— Check the injury column or choose the type of

illness (M)

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Recording a “Medical Treatment” Case

Check the column under “Remained at work - Other Recordable cases” (J)— Check the injury column or choose the type of

injury (M)

Medical treatment is the management and care of a patient to combat disease or a disorder.

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Days Away From Work

A “days away from work” case may mean the employee: — Cannot work due to injury or illness— Is placed on restricted duty or assigned to

another job temporarily• Note that OSHA 300 entry is under separate column

from “days away from work”— Cannot work full-time— Cannot perform all duties on his/her permanent

job

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Days Away From Work (continued)

Do NOT count as days away from work:— The initial day of injury or illness

DO count days the employee would not normally work including vacation, holidays, weekends, etc. IF they weren’t able to do so— If an injured worker takes vacation during the

disability period, that time counts as lost time

Disability management planning STILL vital!

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Days Away From Work (continued)

Day count ceases if employee is terminated for reasons unrelated to injury/illness

Work schedules cannot be manipulated to avoid lost time accumulation

Extended cases defined as “180 or >”— If treating HC provider diagnoses 2 weeks L.T., and worker

recovers sooner, signed verification from provider needed to stop count of LT days.

Update the log if you go over year end Keep for 5 years

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Recording a Lost Time (LWD) Case

Check the box under the column for “Days Away From Work ” (H)— Check the injury column or choose the type of

injury (M)

Enter the number of days away from work in column (L)— Can be estimated for a long absence and

updated when actual number is known— Must count all calendar days including weekends,

holidays, vacations days etc. regardless of the employees work schedule.

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Recording a Job Transfer or Restricted Case

Restricted work activity occurs when — an employee is kept from performing one or more routine functions of the

job or— an employee is kept from working a full day

Check the column under “Remained at work” - “Job Transfer or Restriction” (I)— Check the injury column or choose the type of injury (M) — Enter the number of days in column (K)

Job Transfers must involve change in duties and tasks for portion of workday

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Cases of Medical “Removal” Under some OSHA’s standards, cases are

recordable for “medical removal” — e.g.,... Lead, cadmium, methylene chloride, formaldehyde, benzene,

etc.

“Poisoning” (M5) if result of a workplace chemical exposure; other illnesses include

— (2) MSD - On hold until 1/1/2003— (3) Skin Disorders— (4) Respiratory Conditions— (5) Poisoning— (6) Hearing Loss - On hold until 1/1/2003— (7) All others illnesses

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Who Keeps The Records?

Employers for each “establishment” must keep all records— An “establishment” is a single physical location

in operation for 1 year or more, where business, services, or industrial operations are performed

— Does not include parking lots unless work was being performed there at time of injury

— Two distinct operations at one location are treated as separate establishments

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Where Should Records Be Kept?

Records are kept at the establishment where the employee works:— If working offsite, keep records at

establishment where they report to work— If injured at another establishment within the

company, keep records where the injury/illness took place

— If the employee does not report to a regular worksite, keep records at transient worksite or an established central location

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Where Should Records be Kept? (continued)

Log may be kept at an alternate location or by data processing means, as long as:— Alternate location receives information to fill

out log within seven (7) days— Copy of updated log is present at the

establishment — Employee receives a copy from employer if

s/he does not report to or work at a single establishment

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Access to Records Government representatives must be given access

to Forms 300 and 301 — If request is made in person, information must be

provided in hard copy within four (4) hours— If request is made in writing, information must be

provided within 21 days Forms 300 and 301 must also be made available to

employees upon request— If employee (or authorized rep) requests form # 300,

names must be left on— Generally, only 301 is given to employees or

representatives

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Changes to Employer Requirements

Establish procedure for employees to report injuries and illnesses

Prohibited from discriminating against employees who report injuries & Illnesses

With change of ownership, seller must turn over OSHA records to buyer

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Changes to Employee Rights

— Gives employees and their reps. access to portions of Form 301 relevant to the employee they represent

— Requires employers to remove employees’ names before providing data to persons not provided access under the rule

— Privacy rights Prohibits individual employee’s name on Form 300 for

certain types of injuries/illnessesSexual assaults, HIV infections, Mental illness

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Annual Summary Must be verified for accuracy and updated Must be certified by a company official Must be posted (300A) each 2/1-4/30

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Tuberculosis

Cases recordable when employee is exposed to known active TB source and

That employee subsequently contracts the TB infection.

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OSHA Recordkeeping for Occupational Injuries and Illnesses

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