OSHA Recordkeeping Employment Relations Division Occupational

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Employment Relations Division
Occupational Safety and Health Bureau
OSHA Recordkeeping
• “Just because the numbers are good doesn’t
mean anything. There are three ways to
continuously improve performance numbers.
One is to continuously improve processes, one is
to get lucky, and the other is to lie. If you aren’t
dedicated to improving processes, you’re doing
one of the other two.”
o
Dr. W. Edwards Deming Author and Consultant.
• Identify the OSHA requirements for
recordkeeping, posting and reporting
• Acquire an understanding of the OSHA 300,
300A and 301.
• Required since 1971
• Key provisions of the OSHA rules for recording
injury and illness cases
• 29 CFR 1904 new in 2002, changed in 2003
(hearing loss), and again in 2004 (form update)
• Rumored changes in 2010
• National Emphasis for 2009
• The system is simpler and provides better
resources than the old system
• Greater employer flexibility determining
recordability
• Some aspects reduce ORIs, some increase
ORI’s
• Day counts are not comparable to previous years
due to changes
• If your company had 10 or fewer
employees at all times during the last
calendar year, you do not need to keep the
injury and illness records unless surveyed
by OSHA or BLS
• The size exemption is based on the
number of employees in the entire
company
• Include temporary employees who you
supervised on a day to day basis in the
count
• All industries in agriculture, construction,
manufacturing, transportation, utilities and
wholesale trade sectors are covered
• In the retail and service sectors, some
industries are partially exempt
• Employees on payroll
• Employees not on payroll who are supervised
on a day-to-day basis
• Exclude self-employed and partners
• Temporary help agencies should not record
the cases experienced by temp workers who
are supervised by the using firm
• Keep a separate OSHA Form 300 for each
establishment that is expected to be in
operation for more than a year
• May keep one OSHA Form 300 for all shortterm establishments
• Each employee must be linked with one
establishment
• Easily accessible information in a condensed
format
• A thumbnail sketch of the things causing harm to
employees
• Helps employers “recognize hazards causing or
likely to cause harm”
• Helps inspectors focus their audits
• OSHA's Form 300, the Log of Work-Related
Injuries and Illnesses (replaced the OSHA 200) –
information on injuries and illnesses in a
condensed format
• The 301 form (replaced the OSHA 101) –
detailed record of each case recorded on the 300
form
• Form 300A is the summary of work-related injury
and illness cases. This is the form that is posted
every year for the previous year’s log
• The OSHA 301 “Injury and Illness Incident
Record” provides detailed information about:
o
o
o
o
the affected worker,
the injury or illness,
the workplace factors associated with the accident,
a brief description of how the injury or illness
occurred.
• Equivalent workers' compensation “First Report”
form or internal forms are okay, so long as all of
the same information is included.
• Summarizes entries from the Form 300 Log
• Post February 1 – April 30 of the following year
• Gives employees an overview of the actual
hazards in their workplace
• Contains totals for each column from the Form
300, plus the average number of employees and
total hours worked
• Certification of the data by a company executive
is required.
NOTE: By law, the 300A must be signed by an
“executive” of the company – Not a designee.
• Record every fatality, injury or illness that meets
these criteria:
o
o
o
Work-related,
A new case,
Meets one of the general or specific recording criteria
found in the regulation.
• The same requirements now apply to both
injuries and illnesses.
• Aggravation of a Pre-existing condition is “work
related” and recordable when a work event or
exposure causes one of the following
(Presuming that this outcome would not have
occurred without the work event or exposure):
death
loss of consciousness
a day or days away from work, restricted work or job
transfer
o medical treatment or a change in the course of
medical treatment.
o
o
o
• An injury or illness that occurs while an
employee is on travel status is work-related if it
occurred while the employee was engaged in
work activities in the interest of the employer
• Home away from home
• Detour for personal reasons is not work-related
• Injuries and illnesses that occur while an
employee is working at home are work-related if
they:
o
o
occur while the employee is performing work for pay
or compensation in the home, and
they are directly related to the performance of work
rather than the general home environment
• A case is new if:
The employee has not previously experienced a
recordable injury or illness of the same type that
affects the same part of the body; or
o The employee previously experienced a recordable
injury or illness of the same type that affects the same
part of the body, but had recovered completely and an
event or exposure in the work environment caused
the signs and symptoms to reappear
o If there is a medical opinion regarding resolution of a
case, the employer must follow that opinion
o
• Cases occurring on the work premises are presumed to be
work-related except when they involve:
o
o
o
o
o
o
o
o
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Eating, drinking or preparing food or drink
Common colds and flu
Voluntary participation in wellness program, medical, fitness, or
recreational activity
Mental illness (unless employee voluntarily provides an opinion from
a licensed health care professional stating condition is work related)
Employee is at work as a member of the general public rather than
as an employee.
Symptoms surface at work but result solely from a non-work-related
event or exposure.
Doing personal tasks at work outside normal work hours.
Grooming, self-medication, or intentionally self-inflicted.
A motor vehicle accident on a company parking lot or company
access road while commuting to or from work
•
•
•
•
•
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Death
Days away from work
Restricted work or job transfer
Medical treatment beyond first aid
Loss of consciousness
Diagnosis by a PLHCP as a significant injury or
illness
• Record if the case involves one or more days
away from work
• Check the box for days away cases and count
the number of days
• Do not include the day of injury/illness
• Restricted work activity occurs when:
An employee is kept from performing one or more
routine functions (work activities the employee
regularly performs at least once per week) of his
or her job; or
o An employee is kept from working a full workday;
or
o A PLHCP recommends either of the above
o
• Job Transfer
An injured or ill employee is assigned to a job other
than his or her regular job for part of the day
o A case is recordable if the injured or ill employee
performs his or her routine job duties for part of a day
and is assigned to another job for the rest of the day
o
• Medical treatment is the management and care
of a patient to combat disease or disorder
• It does not include:
o
o
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Visits to a PLHCP solely for observation or counseling
Diagnostic procedures
First aid
• Using nonprescription medication at nonprescription
strength
• Tetanus immunizations
• Cleaning, flushing, or soaking surface wounds
• Wound coverings, butterfly bandages, Steri-Strips
• Hot or cold therapy
• Non-rigid means of support
• Temporary immobilization device used to transport
accident victims
• Drilling of fingernail or toenail, draining fluid from blister
• Eye patches
• Removing foreign bodies from eye using irrigation or
cotton swab
• Removing splinters or foreign material from areas other
than the eye by irrigation, tweezers, cotton swabs or
other simple means
• Finger guards
• Massages
• Drinking fluids for relief of heat stress
• All work-related cases involving loss of
consciousness must be recorded
• Includes all punctures, cuts and lacerations caused
by needles or other sharp objects contaminated (or
presumed contaminated) with blood or OPIM
• Such injuries may later cause diseases like AIDS,
hepatitis B and hepatitis C and must be monitored
• Does not require the recording of all cuts and
punctures. (e.g.: A cut made by a knife or other
sharp object not contaminated by blood or OPIM
would not be recordable if only first aid was
required)
CURRENT RULE:
• 10 dB loss from original
or revised baseline in
either ear ONLY when
accompanied by an
overall 25 dB shift from
audiometric zero (normal
hearing)
OLD RULE:
• 25 dB loss from original
or revised baseline in
either ear
Both based upon average of audiometric results at 2000, 3000 & 4000 Hz
Both allow age adjustments according to the Hearing Conservation Standard
• MSD cases like carpal tunnel syndrome are
recordable on the 300 log if they meet general
recording criteria
• Employer retains flexibility to determine whether
an event or exposure in the work environment
caused or contributed to the MSD
• Must record cases when there is a known
exposure to tuberculosis and an employee
develops a tuberculosis infection.
• Must record a case on the OSHA 300 Log
whenever an employee is medically removed
under the medical surveillance requirements of
any OSHA standard.
• Must be recorded as a case involving days away
from work or as a case involving restricted work
activity, depending upon the removal
requirements
• Count “days away” or “days restricted or
transferred” for every day after the date of
incident or onset (the day of injury or illness is
not counted)
• Count all calendar days, including weekends,
holidays, shutdowns and vacations
• There is a limit on how long employers are
required to track cases. Days away or days of
restriction do not have to be counted beyond 180
days, total for both categories
• Employers must inform employees of how to report
an injury or illness.
• Employers are prohibited from discriminating against
employees for reporting injuries and illnesses.
• Employees may access the 301 forms for their own
cases
• Employee representatives now have a right to view
the right-hand column of the OSHA 301
• Employees, former employees, and employee
representatives (union, attorney, physician, etc.)
have a right to view a copy of the Log
• Employers must withhold the employee's name from
the OSHA log for "privacy concern cases"
• A separate list of case numbers and employee
names must be provided to OSHA upon request
• Privacy concern cases include:
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Intimate body part or reproductive system
Resulting from a sexual assault
Mental illness
Communicable diseases (HIV, hepatitis, tuberculosis)
Contaminated Needlestick and sharps injuries
Other merited employee requests
• The Form 300A must be certified at the end of
each year
• It must be posted from February 1 until April 30
of the year following
• A company executive must certify the accuracy
of the data
• Must report fatalities and hospitalizations of three of
more employees to OSHA within 8 hours.
• The report must be made to the OSHA area office or
the toll free number 1-800-321-6742 (OSHA).
• Clarifications in the rule relating to reporting:
o
o
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Employers must report fatal heart attacks that occur at work
Employers do not have to report motor vehicle accidents
that occur in a public street
Employers do not have to report public transport accidents
• Even when accidents are not reportable, they are
recordable if they meet OSHA's recordability criteria.
•
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•
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Days Away From Work
Days of Restricted Work Activity
Job Transfer
Formula:
o
Number of entries in Column H x 200,000/Number of
hrs worked by all employees = DART incidence rate
• Incidence rate for all recordable cases of injuries
and illnesses
• Formula:
o
Total number of injuries & illnesses x 200,000/Number
or hrs worked by all employees = Total recordable
case rate
• Information is constantly changing – bookmark
and refer to this webpage:
www.osha.gov
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