Transcript OSHA Recordkeeping Training – New Regulation

OSHA Recordkeeping Training –
New Regulation
Course Outline
1.0
2.0
3.0
4.0
Overview
Recording Injuries & Illnesses
Maintenance & Retention of Records
Posting Requirements
1.0 Overview
Federal OSHA, under Clinton
Administration, made changes to the
requirements for recording work related
injuries and illnesses.
 California must adopt a regulation as
effective by the end of December.

“Records” Consist of Three
Forms
OSHA 300: Log of Occupational Injuries
and Illnesses
 OSHA 300A : Annual Summary of
Occupational Injuries and Illnesses
 OSHA 301: The Supplementary Record of
Occupational Injury and Illnesses.
Equivalent to Form 5020, Employer’s
Report of Occupational Injury or Illness

2.0 Recording Injuries &
Illnesses
“Recordable” Cases only
 Recording an injury or illness under the
OSHA System does not imply that an
employer was at fault, that the worker was
at fault, that a violation of an OSHA
standard has occurred. Or that the injury or
illness will be compensable under Workers’
Compensation. It is not an admission of
liability.
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Key Terms
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Recordable: Any work-related injury or illness
in the work environment that is a new case and
results in:
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Loss of consciousness
Restricted work activity or job transfer
Days away from work not counting the day of injury
Medical treatment beyond first aid
Fatality
Diagnosed occupational illness
Definition
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Work Environment – The establishment &
other locations where one or more
employees are working or are present as a
condition of their employment. The work
environment includes not only physical
locations, but also the equipment or
materials used by an employee during the
course of his/her work.
Clarification – Work
Environment is Not:
If the employee was injured when in the
work environment as a member of the
general public
 The injury/illness involves signs or
symptoms that surface at work but result
solely from a non-work-related event that
occurs outside the work environment
 The injury/illness results solely from
voluntary participation in a wellness
program or in a medical, fitness, or
recreational activity

Clarification – Work
Environment is Not:
The injury/illness is solely the result of an
employee eating, drinking, or preparing
food or drink for personal consumption.
 The injury/illness is solely the result of an
employee doing personal tasks at the
establishment outside of the employee’s
assigned working hours.
 The injury/illness is solely the result of
personal grooming, self-medication for a
non-work-related condition or is
intentionally self-inflicted.
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Clarification – Work
Environment is Not:
The injury/illness is caused by a motor
vehicle accident & occurs on a company
parking lot or company access road while
the employee is commuting to/from work.
 The illness is the common cold or flu.
 The illness is a mental illness unless a
psychiatrist or psychologist has stated that
the employee has a mental illness that is
work-related.
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Definition
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New Case:
– The employee has not previously experienced a
recorded injury/illness of the same type that affects the
same body part, or
– The employee previously experienced a recorded
injury/illness of the same type that affected the same
part of the body but had recovered completely from the
previous injury/illness and an event or exposure in the
work environment caused the signs or symptoms to
reappear
New Case Clarification
For occupational illnesses where the signs
or symptoms may recur or continue in the
absence of an exposure, the case must only
be recorded once.
 The episode is a new case if the symptoms
(e.g., occupational asthma) are the result of
an event or exposure
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Definition
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Medical Treatment: The management & care of a
patient to combat disease or disorder.
Does not include:
– Visits to a physician solely for observation or
counseling
– Diagnostic procedures such as x-rays or blood tests,
including the administration of prescription medications
used solely for diagnostic purposes (e.g., eye drops to
dilate pupils).
– First Aid Treatment
Definition
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First Aid:
– Using a nonprescription medication at nonprescription
strength
– Administering tetanus immunizations (other
immunizations such as Hepatitis B vaccine are
considered medical treatment)
– Cleaning, flushing or soaking wounds on the surface of
the skin
– Using wound coverings such as bandages, Band-Aids,
gauze pads, butterfly bandages, or Steri Strips (sutures,
staples, etc are considered medical treatment)
Definition Continued:
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Using hot or cold therapy
Using any non-rigid means of support, such as
elastic bandages, wraps, non-rigid back belts
(devices with rigid stays are considered medical
treatment)
Using temporary immobilization devices while
transporting an accident victim
Drilling of a fingernail or toenail to relieve
pressure, or draining fluid from a blister
Using eye patches
Definition Continued:
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Removing foreign bodies from the eye using only
irrigation or a cotton swab
Removing splinters or foreign material from areas
other than the eye by irrigation, tweezers, cotton
swabs, etc.
Using finger guards
Using massages (physical therapy or chiropractic
treatment are considered medical treatment)
Drinking fluids for relief of heat stress
Definition
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Pre-existing Conditions: An injury/illness
is a pre-existing condition if it resulted
solely from a non-work-related event or
exposure that occurred outside the work
environment
More Recordables
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A pre-existing injury/illness should be recorded if
it is significantly aggravated when an
event/exposure in the work environment results in
any of the following:
– Death, provided that the pre-existing injury/illness
would likely not have resulted in death but for the
occupational event or exposure
– Loss of consciousness
– One or more days away from work, or days of restricted
work, or days of job transfer
– Medical Treatment if not needed before the workplace
event or exposure
Travel
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Injuries or Illnesses that occur while an
employee is on travel status are workrelated if, at the time of the injury/illness,
the employee was engaged in work
activities “in the interest of the employer.”
– Examples include: travel to/from customer
contacts, entertaining or being entertained to
transact, discuss, or promote business, seminars
or conferences
Travel Clarification
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Not work related when:
– Employee is checking into a hotel, motel, or
other temporary residence
– Employee is on a personal detour from a
reasonably direct route of travel (e.g., has taken
a side trip for personal reasons)
Working at Home
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Injuries/Illnesses that occur while an
employee is working at home will be
considered work-related if the injury/illness
occurs while the employee is performing
work for pay or compensation in the home,
and the injury/illness is directly related to
the performance of work rather than to the
general home environment or setting.
New Recordables
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Tuberculosis if evidenced by a positive skin test or
diagnosed by a physician
Medical Removal – Employee is removed from a
their position under a medical removal provision
in Title 8 regardless of the presence of diagnosis
of an injury/illness. Must be recorded as days
away from work or restricted work activity. Use
column “poisoning” (e.g., benzene, cadmium,
methylene chloride, lead, formaldehyde)
New Recordables Continued
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Needlestick and Sharps Injuries
– All work-related needlestick injuries and cuts from
sharp objects that are contaminated with another
person’s blood or other potentially infectious material
should be entered as an injury. To protect privacy,
employee’s name may not be entered on OSHA 300 log
instead enter “privacy case.”
– If employee is diagnosed with an infectious bloodborne
disease, update description and change classification
from an injury to an illness
– If employee is splashed with blood or OPIM, record if
it results in a bloodborne illness
Definition
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Privacy Concern Case:
– Injury/illness to an intimate body part or the
reproductive system
– Injury/illness resulting from a sexual assault
– Mental illnesses
– HIV Infection, hepatitis, or tuberculosis
– Needlestick injuries and cuts from sharp objects
– Illnesses in which an employee independently
and voluntarily requests that his/her name not
be entered on the log
Rules for Counting Lost Days
Count calendar days and cap at 180
 Do not include day of injury
 Stop counting if a physician release an
employee to work but employee fails to
show up
 Special circumstances –injury before
vacation or weekend
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Rules for Counting Restricted
Days or Transfer Days
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Record if employee is kept from performing one
or more routine duties
Do not have to record if restriction is only for day
of injury
Recommended restrictions are only recorded if
employee is kept from performing one or more
routine job duties
A partial shift because of an injury is counted as a
day of restriction
Stop counting if employee’s job has been
permanently modified or changed
Count calendar days and cap at 180
3.0 Maintenance & Retention of
Records
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Each department must maintain their own
OSHA 300s, 300As and 301s. Records
must be maintained centrally but must be
made available upon request to any
employee, former employees, authorized
employee representative, or Cal/OSHA
inspector.
OSHA 300
Recordable entries must be made within
seven (7) calendar days after receiving
information that a recordable injury/illness
has occurred.
 Any changes to previous entries must also
be made within seven (7) calendar days of
dutiful knowledge of such a change.
 The log must be kept complete and updated
to within 45-calendar days.
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OSHA 300 Continued
All log totals must be adjusted accordingly
to reflect any changes.
 Must be retained for 5 years and must be
updated to include newly discovered
recordable injuries/illnesses and any
changes in classification of injury/illness
 Send to City Safety Office at the
beginning of each month
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OSHA 300A
Total columns G – M on OSHA 300 and
transfer to 300A at the end of the calendar
year
 Does not have to be updated during 5 year
storage
 Must be signed by City Safety Officer, City
Manager, Assistant City Manager, or
Deputy City Manager
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OSHA 301
Departments must complete and file this
form within seven (7) calendar days of
receipt of information on a recordable injury
or illness
 May use 5020 in lieu of 301
 Must be retained for five (5) years
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4.0 Posting Requirements
Only Form 300A is posted
WHY: Employee right to information
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WHERE: Conspicuous place or places where
employee notices are customarily posted
WHEN: From February 1 to April 30
Target Dates
Begin logging injuries/illnesses on 300 Log
starting January 1
 Use OSHA 200 Log for calendar year 2001
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The End
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Questions
Exercise
Thank you for
attending!