Transcript OSHA Recordkeeping - Hettrick, Cyr & Associates, Inc.

NEW OSHA RECORDKEEPING
STANDARD
<Insert Company Name>
Prepared by:
Hettrick, Cyr & Associates, Inc.
BENEFITS OF THE RULE
Improves employee involvement
 Creates simpler forms
 Provides clearer regulatory requirements
 Increases employers’ flexibility to use
computers
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DAY COUNTS
Eliminates the term “lost workdays” and
focuses on days away or days restricted or
transferred
 Includes new rules for counting that rely on
calendar days instead of workdays
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RECORDING CRITERIA
 Eliminates
different criteria for
recording work-related injuries and
work-related illnesses
 Former rule required employers to
record all illnesses, regardless of
severity
LOG REPORTING CHANGES
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NEW “300” log simplified
Supplementary Record (OSHA 301)
Annual Summary (OSHA 300A); 3 Month Posting –
2/1 thru 4/30
Signed By Company Executive
Access to OSHA 301 for Employee Representatives
(without personal identifiers)
All Entries Within 7 Calendar Days
Day count by calendar days;180 days maximum
“Lost Work Day” language eliminated
NEW FORMS MUST BE USED BEGINNING
1/1/2002
RECORDING CRITERIA
DECISION TREE
NO
Did the e m ploye e e xpe rie nc e a n
injury or illne ss?
YE S
NO
Is the injury or
illne ss work-re la te d?
YE S
NO
Is the injury
or illne ss a ne w c a se ?
Upda te the pre viously
re c orde d injury or illne ss
e ntry if ne c e ssa ry.
YE S
NO
Do not re c ord the
injury or illne ss
Doe s the injury or illne ss m e e t
the ge ne ra l re c ording c rite ria
or the a pplic a tion to spe c ific c a se s?
YE S
Re c ord the
injury or illne ss
WORK RELATEDNESS
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Cases are work-related if:
– An event or exposure in the work environment
either caused or contributed to the resulting
condition
– An event or exposure in the work environment
significantly aggravated a pre-existing injury or
illness
WORK RELATED EXCEPTIONS
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Adds additional exceptions to the definition
of work relationship to limit recording of
cases involving:
– eating, drinking, or preparing food or drink for
personal consumption
– common colds and flu
– voluntary participation in wellness or fitness
programs
– personal grooming or self-medication
OSHA RECORDABLES
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Death
Loss of consciousness
Days away from work
Restricted work activity or job transfer
Medical treatment beyond first aid
“Significant” work related injuries/illnesses as
defined by physician
 Additional criteria
RECORDING NEEDLESTICKS
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Requires employers
to record all
needlestick and
sharps injuries
involving
contamination by
another person’s
blood or other
potentially infectious
material
HEARING LOSS
 Requires
employers to record 25 dB
shifts in employees’ hearing during
2002
 OSHA will reconsider the hearing loss
criteria for 2003 and beyond
MUSCULOSKELETAL DISORDERS
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Applies the same recording criteria to
musculoskeletal disorders (MSDs) as to all other
injuries and illnesses
Employer retains flexibility to determine whether
an event or exposure in the work environment
caused or contributed to the MSD
OSHA will use the one-year delay to develop
definitions of ergonomic injury and MSD
consistent with a comprehensive effort
TUBERCULOSIS & MEDICAL
REMOVAL
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Includes separate
provisions describing the
recording criteria for cases
involving the work-related
transmission of
tuberculosis
Requires employers to
record cases of medical
removal under OSHA
standards
FIRST AID NON RECORDABLES,
1986 - 2001
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Application of Antiseptics during
first visit to medical personnel
Treatment of First Degree Burns
Application of Bandages during
any visit to medical personnel
Use of Elastic Bandages during
first visit to medical personnel
Removal of Foreign Bodies from
wound; if procedure is
uncomplicated, and is, for
example, by tweezers or other
simple technique
Use of Non Prescription
Medication and administration of
single dose of Prescription
Medication on first visit for minor
injury or discomfort
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Soaking Therapy on initial visit
to medical personnel or removal of
bandages by Soaking
Application of hot or cold
Compresses during first visit to
medical personnel
Application of Ointments to
abrasions to prevent drying or
cracking
Application of Heat Therapy
during first visit to medical
personnel
Negative X-Ray diagnosis
Observation of injury during visit
to medical personnel
Administration of Tetanus Shots
or Boosters without serious injury
FIRST AID NON RECORDABLES,
1/1/2002
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Using non-prescription
medications at non-prescription
strength
Administering tetanus
immunizations
Cleaning, flushing, or soaking
wounds on the skin surface
Using wound coverings, such as
bandages, BandAids, gauze
pads, etc., or using SteriStrips
or butterfly bandages
Using hot or cold therapy
Using any totally non-rigid
means of support, such as
elastic bandages, wraps, nonrigid back belts, etc.
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Using temporary
immobilization devices while
transporting an accident victim
(splints, slings, neck collars, or
back boards)
Drilling a fingernail or toenail
to relieve pressure, or draining
fluids from blisters
Using eye patches
Using simple irrigation or a
cotton swab to remove foreign
bodies not embedded in or
adhered to the eye
Using finger guards
FIRST AID NON RECORDABLES,
1/1/2002
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Using irrigation, tweezers, cotton swab, or other simple
means to remove splinters or foreign material from areas
other than the eye
Using massages (physical therapy or chiropractic treatment
considered medical treatment under new standard)
Drinking fluids to relieve heat stress
THIS IS A COMPLETE LIST OF ALL TREATMENTS
CONSIDERED FIRST AID, NON-RECORDABLE
MEDICAL TREATMENT RECORDABLES
1986 - 2001
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Treatment of Infection
Application of Antiseptics during
second or subsequent visit to medical
personnel
Treatment of Second or Third Degree
Burns
Application of Sutures (Stitches)
Application of Butterfly Adhesive
Dressings or Steri Strips in lieu of
sutures
Removal of Foreign Bodies Embedded
in Eye
Removal of Foreign Bodies from
Wound; if procedure is complicated
because of depth of embedment, size, or
location
Use of Prescription Medications (except
a single dose administered on first visit
for minor injury or discomfort
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Use of hot or cold Soaking Therapy
during second or subsequent visit to
medical personnel
Application of hot or cold Compresses
during second or subsequent visit to
medical personnel
Cutting away Dead Skin (surgical
debridement)
Application of Heat Therapy during
second or subsequent visit to medical
personnel
Use of Whirlpool Bath Therapy during
second or subsequent visit to medical
personnel
Positive X-Ray diagnosis (fractures,
broken bones, etc.)
Admission to a Hospital or equivalent
medical facility for treatment
MEDICAL TREATMENT
The Management and Care of a Patient to
Combat Disease or Disorder
Not Considered Medical Treatment:
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Visits to a doctor or health care professional solely for observation or
counseling
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The conduct of diagnostic procedures, such as x-rays and blood tests,
including the administration of prescription medications used solely
for diagnostic purposes (e.g., eye drops to dilate pupils; or
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First Aid as defined in the new standard
EMPLOYEE PRIVACY
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Prohibits employers from entering an individual’s
name on Form 300 for certain types of
injuries/illnesses
Provides employers the right not to describe the
nature of sensitive injuries where the employee’s
identity would be known
Gives employee representatives access only to the
portion of Form 301 which contains no personal
information
Requires employers to remove employees’ names
before providing the data to persons not provided
access rights under the rule
PRIVACY CASE ENTRIES
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Injury or illness to an intimate body part or to
reproductive system
Injury or illness resulting from sexual assault
A mental illness
HIV infection, hepatitis, or TB
A needlestick or sharps contaminated by blood or
infectious material
Voluntary employee request of illness case
RECORD “PRIVACY CASE” IN NAME COLUMN
EMPLOYEE INVOLVEMENT
Requires employers to establish a procedure
for employees to report injuries and
illnesses and tell their employees how to
report
 Employers are prohibited from
discriminating against employees who do
report
 Employee representatives will now have
access to those parts of the OSHA 301 form
relevant to workplace safety and health
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REPORTING TO OSHA
 Changes
the reporting of fatalities and
catastrophes to exclude some public
transportation and motor vehicle
accidents, but adds heart attack
fatalities