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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
Purpose and Intent of the Standard

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
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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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 contract
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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
Recording Criteria (Decision Tree)
NO
Did the employee experience an
injury or illness?
YES
NO
Is the injury or illness
work related?
YES
Is the injury or illness
a new case?
Update the previously
recorded injury or illness
entry if necessary
YES
NO
Do not record the
Injury or illness
Does the injury or illness meet the
general recording criteria or the
application to specific cases?
YES
Record the injury
or illness
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OSHA 2002 Recordkeeping Safety Training Workshop
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 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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
Determining Work Relatedness:
Telecommuting from Home

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.
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OSHA 2002 Recordkeeping Safety Training Workshop
What is a “New” Injury or Case?


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)
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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
Site Controlling Employer/ SCE
(continued)



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.
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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
Days Away From Work (continued)

Do NOT count as days away from work:
—

DO count days the employee would not
normally work including vacation, holidays,
weekends, etc. IF they weren’t able to do so
—

The initial day of injury or illness
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
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/illnesses
Sexual assaults, HIV infections, Mental illness
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OSHA 2002 Recordkeeping Safety Training Workshop
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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OSHA 2002 Recordkeeping Safety Training Workshop
Tuberculosis


Cases recordable when employee is
exposed to known active TB source and
That employee subsequently contracts
the TB infection.
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