Transcript OSHA Recordkeeping Scenarios Brian A. Zachetti, CSP

Mahoning Valley
Safety Council
Answers To Recordkeeping Questions
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Contact the local office of the Division of Safety & Hygiene
Contact the local OSHA office
1. Toledo 419-259-7542
2. Cleveland 216-522-3818
3. Columbus 614-469-5582
4. Cincinnati 513-841-4132
Contact the Bureau of Labor Statistics in Washington DC
at 202-693-1702
Dave Schmidt OSHA Office of Statistical Analysis
202-693-1886 or [email protected]
Rex Tingle OSHA Office of Statistical Analysis
(202-693-1926) or [email protected]
Brian Zachetti 330-904-7754 or [email protected]
7/7/2015
Ohio BWC Employer Management
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7/7/2015
Ohio BWC Employer Management
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7/7/2015
Ohio BWC Employer Management
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7/7/2015
Ohio BWC Employer Management
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OSHA Recordkeeping Scenario 1
 John
Shaw, a press operator, in the
Press Room, was killed on
Wednesday, January 2. He was
caught in the point of operation in a
mechanical power press. The press
accidentally cycled while he was
inside of the machine removing a
part.
OSHA Recordkeeping Scenario 1
 Work-related
fatalities are recordable
 Record work-related fatalities by
entering a check mark in the death
column on the OSHA 300 Log
 Workplace fatalities and multiple
hospitalizations (3 or more) from
same incident must be reported to
OSHA.
OSHA Recordkeeping Scenario 2
 Kate
Davis, an office clerk, lost
consciousness on Friday, January 11.
She hyperventilated and passed out
for approximately 3 minutes when she
read an email from her boss
indicating that all staff would be
placed on mandatory overtime for the
next 4 weeks.
OSHA Recordkeeping Scenario 2
 Any
work-related injury or illness
which involves a loss of
consciousness, no matter how short,
must be recorded unless it applies to
1 of the 9 exemptions in 1904.5(b)(2).
OSHA Recordkeeping Scenario 3
 R.J.
McDuck, a warehouse worker,
stepped on a board with exposed
nails on Monday, January 14, cutting
his left foot. He was sent to the
hospital and the wound was covered
with steri-strips and treated with a
tetanus shot. The doctor told him to
return to work in 10 days.
OSHA Recordkeeping Scenario 3

Work-related cases involving “days away
from work” are recordable. A case is a
days away from work case:
 If the employee could not have worked on any
day after the injury or onset of illness – whether
or not there was scheduled work
 Count the number of calendar days the
employee was unable to work regardless of the
schedule
 Cap at 180 days
OSHA Recordkeeping Scenario 4
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Barb Johnson, a packer in the shipping
department, was lifting a box on Wednesday,
January 30, when she felt a pain in her back.
She reported it immediately to her
supervisor. Her supervisor asked her if she
wanted to see a doctor and she said “no”.
Two days later she said it still hurt so she
went to the doctor. The doctor diagnosed a
strain and recommended she go back to
work but avoid lifting for a week and said to
return if it did not improve.
OSHA Recordkeeping Scenario 4
A “Job Restriction” occurs when, because
of the injury or illness, the employer or a
PLHCP keeps the employee from
performing one or more of the “routine
functions” of their job, or from working the
full work day
 A “Job Transfer” occurs when an injured or
ill employee is assigned to a job other than
his/her regular job
 An employee’s “routine functions” are
those work activities the employee
regularly performs at least once a week.
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OSHA Recordkeeping Scenario 5
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Pete Barnett, a grinder operator, in
Department 6, lacerated his left
forefinger using a portable grinder on
Tuesday, February 5. He was sent to
the Walk-In Department at the local
clinic. It took eight (8) stitches to close
the wound. When he returned to work
the next day the doctor’s slip asked him
to return in ten (10) days for removal of
the stitches. It also said to keep the
hand clean.
OSHA Recordkeeping Scenario 5
First Aid Treatments
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Non-prescription drugs in nonprescription strength
Administering a tetanus, (others
like Hep B and rabies are
recordable)
Cleaning, flushing or soaking
wounds on the surface of the skin
Using wound coverings such as
adhesive bandages, gauze pads,
etc., or using butterfly bandages
or steri-strips.
Using hot or cold therapy
Using non-rigid means of support,
such as elastic bandages, wraps,
non-rigid back belts, etc.
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Drilling of a fingernail or toenail or
draining a blister
Using an eye patch
Removing foreign body 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, or other simple means
Use of finger guards.
Using massages (physical therapy
and chiropractic treatment are
considered medical treatment.
Drinking fluids for relief of heat
stress.
OSHA Recordkeeping Scenario 6
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Mike Hartman, a powered industrial
truck operator, in the Packing
Department, reported on Tuesday,
February 12, that his left hand was
sore. He did not relate to a specific
incident. He said it had become
increasingly worse over the past
week. He was sent to the doctor and
returned with a note requesting that
he receive therapy twice a week; wear
a brace on his hand; and return to
work in two (2) weeks.
OSHA Recordkeeping Scenario 6
If an injury/illness results from an event or exposure in the work
environment, work-relatedness is “presumed” Exemptions:
1.
Occurs when the employee is present in the work environment
as a member of the general public
2.
Results solely from voluntary participation in a wellness program,
or in a medical, fitness, or recreational activity
3.
Involves signs and symptoms that surface at work, but result
solely from a non-work-related event or exposure
4.
Is solely the result of an employee eating, drinking, or preparing
food or drink for personal consumption
5.
Is solely the result of an employee doing personal tasks at the
establishment outside of the employee’s assigned working hours
6.
Is solely the result of personal grooming, self-medication for a
non-work-related condition, or is intentionally self-inflicted
7.
Is caused by a vehicle accident and occurs on a company
parking lot or access road while the employee is commuting
8.
Is the common cold or flu
9.
Is a mental illness (unless specific situations apply)
OSHA Recordkeeping Scenario 7
 John
Matune, a banker, in the
Finance Department, pulled his back
lifting a box on Thursday, February
14. The company physician, an MD,
recommend John take 200MG
Ibuprofen daily, apply ice every 2
hours, and return to work at full duty
the next day. John’s personal
chiropractor recommended that John
spend 4 days away from work resting.
OSHA Recordkeeping Scenario 7
Conflicting Medical Opinions
 If there are two different medical
opinions that conflict, the employer
must make a decision as to which
recommendation is the most
authoritative
 Generally, the PLHCP with more
knowledge and experience is the
most authoritative
OSHA Recordkeeping Scenario 8
 Thomas
Niles, a Safety Director, in
the Human Resources Department,
suffered a fractured cheek bone on
Monday, February 18 after his boss
Tim Williams “accidently” elbowed
him in the face. Thomas saw a doctor
but no medical treatment, days away,
or restriction were recommend.
OSHA Recordkeeping Scenario 8
Significant Injuries or Illnesses are always
recordable
 OSHA’s definition of Significant
Injury/illness is limited to the following
work-related conditions:
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 Fractured or cracked bones (including teeth)
 Punctured ear drum
 Chronic irreversible disease
 Occupational cancer
OSHA Recordkeeping Scenario 9
 John
Picciano, a Forensic DNA
Analyst, in the Laboratory, had a
needle stick injury contaminated with
blood on his left hand on Tuesday
February 26. No medical treatment,
days away, or restrictions were
recommended. On August 18, blood
tests confirmed that John had
contracted Hepatitis B from the
needle stick incident.
OSHA Recordkeeping Scenario 9
Work-related needle sticks and cuts
from sharp objects that are
contaminated with blood or potentially
infectious material are recordable as an
injury
 If the employee is later diagnosed with a
bloodborne disease, the system must be
updated to reflect the new outcome and
changed to an illness
 This type of case must also be recorded
as a privacy case. (Discussion)
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OSHA Recordkeeping Scenario 10
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Dan Galbreath is a fishing lure
manufacturing employee in the molding
department. Dan is included in a
mandated employer medical
surveillance program for lead. On
Thursday, March 7 Dan’s first blood test
indicated that his blood lead level was
45ug/100 g of whole blood. No medical
treatment or time off was recommended
but Dan’s employer removed him from the
workplace voluntarily until his blood lead
level was under 40ug/100g.
OSHA Recordkeeping Scenario 10
 If
an employee is medically removed
under the medical surveillance
requirements of a specific OSHA
standard, you must record the case
 If the case involves voluntary medical
removal before the criteria are met,
you do not need to record the case
OSHA Recordkeeping Scenario 11
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Al Margoni, a fabricator in the machining
department, had his annual audiogram
in accordance with his employers
hearing conservation program on
Monday, March 11. His hearing levels
were 24db, 18db, and 12db respectively
at 2000hz, 3000hz, and 4000hz for an
average overall hearing level of 18db in
his left ear. This indicates an STS of
10db from his baseline audiogram.
OSHA Recordkeeping Scenario 11
Is the hearing loss work-related?
 Has the employee suffered a Standard
Threshold Shift (an average 10dB loss
relative to the most current baseline at
2000, 3000, and 4000 Hz) in one or both
ears corrected for aging?
 Is the employee’s overall hearing level
at 25dB or more from audiometric zero?
 If yes to all above - RECORD
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OSHA Recordkeeping Scenario 12
 Cindy
Stewart a nurse, in Wing C of a
skilled care facility, developed a case
of Tuberculosis that was diagnosed
by a LPHCP on Wednesday, March
13. There are residents in Wing C
with known active cases of TB. No
missed work days or restrictions were
recommend by her doctor at the time
of diagnosis.
OSHA Recordkeeping Scenario 12
 If
the employee has been
occupationally exposed to anyone
with a known case of active TB, and
the employee subsequently develops
a TB infection (positive skin test or
diagnosis) record the case.
OSHA Recordkeeping Scenario 13
 Aaron
Hinde, the shipping supervisor,
cut his right hand with a utility knife
opening a box in the shipping
department on Tuesday, March 19.
Aaron’s doctor used butterfly
bandages to close the wound and
recommended that he take 5 days off
of work. Aaron did not take the five
days off and came to work anyway.
OSHA Recordkeeping Scenario 13
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You must record these injuries and
illnesses on the OSHA 300 Log using
the check box for cases with days away
from work and enter the number of
calendar days away recommended by
the physician or other licensed health
care professional. If a physician or other
licensed health care professional
recommends days away, you should
encourage your employee to follow that
recommendation.
OSHA Recordkeeping Scenario 14
 Josh
Pearlman, a fitter, in the welding
department of a small welding shop
with 5 employees, was burned on his
left hand by hot metal on Thursday,
March 28. He went to the hospital
where he received burn care and was
given a prescription for hydrocodone
pain killers. The doctor
recommended 30 days away from
work.
OSHA Recordkeeping Scenario 14
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If your company had ten (10) or fewer
employees at all times during the last
calendar year, you do not need to keep
OSHA injury and illness records unless
OSHA or the BLS informs you in writing
that you must keep records. However,
all employers covered by the OSH Act
must report to OSHA any workplace
incident that results in a fatality or the
hospitalization of three or more
employees.
OSHA Recordkeeping Scenario 15
 Lynn
Coletta, a baker at a retail
bakery, slipped on water in the
kitchen on Friday, April 5, tearing her
right rotator cuff. Lynn had surgery
and missed 46 days of work. When
she returned she was placed on
restricted duty for another 50 days.
OSHA Recordkeeping Scenario 15
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If your business establishment is classified in
a specific low hazard retail, service, finance,
insurance or real estate industry listed in
Appendix A to this Subpart B, you do not
need to keep OSHA injury and illness
records unless the government asks you to
keep the records under § 1904.41 or §
1904.42. However, all employers must report
to OSHA any workplace incident that results
in a fatality or the hospitalization of three or
more employees (see § 1904.39).
OSHA Recordkeeping Scenario 15
OSHA Recordkeeping Scenario 16
 Tim
Doran, a recycler at a liquids
recycling center, was cut by a piece of
glass on his right forearm in the
collection room on Wednesday, April
2nd. Tim received 7 stitches and his
doctor recommended no missed work
or restrictions. Tim didn’t come to
work until the following Monday.
OSHA Recordkeeping Scenario 16
 In
this situation, you must only count
the amount days away from work the
physician or other licensed health
care professional recommends.
(Discuss employer given days here)
OSHA Recordkeeping Scenario 17
 Ami
Malovitz, a sales representative,
pulled her back out while working at
home in her office lifting a box of work
documents on Thursday, April 18.
The doctor recommended Ami take 5
days off and not lift any boxes for 2
weeks.
OSHA Recordkeeping Scenario 17
 The
case is work-related if the injury
or illness occurs while the employee
is performing work for pay or
compensation in the home and the
case is directly related to the
performance of work rather than the
general home environment.
(ie..tripping over the family dog)
OSHA Recordkeeping Scenario 18
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Kim Mutkus, a pharmaceutical sales
representative, was in a car accident
while traveling during work hours on
Friday, April 26 at 3:59PM. Kim broke
her neck and is going to miss the next
100 days of work. The doctor
speculates that she may never return to
her normal job. Kim was doing a nonwork related errand several miles from
her normal path of travel during the time
of the accident.
OSHA Recordkeeping Scenario 18
Injuries/illnesses are not work-related in travel
status if they occur while:
1. At the temporary lodging location and not
conducting official business (hotel room =
“home away from home”)
2. Commuting to/from temporary lodging and
the job location
3. Taking a personal detour from the direct
route of business travel
OSHA Recordkeeping Scenario 19
 Tom
Morgan, a general laborer, tore
the meniscus in his right knee while
slipping in a hole. The incident
occurred in the future storage area of
a Dairy Queen construction site, on
Thursday, May 2. Tom is going to
miss the next 260 days for surgery to
repair the right knee.
OSHA Recordkeeping Scenario 19
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Determine the proper number of days
away from work:
 Count the number of calendar days the
employee was unable to work regardless of
the schedule
 Begin counting from the day after the
injury/onset of illness
 Cap at 180 days
OSHA Recordkeeping Scenario 20
 John
Dee, a logistics dispatcher at a
trucking company, aggravated his
previous work related/recorded lower
back injury from 2009. He did it while
turning in his office chair on
Wednesday, May 8. John’s doctor
recommended 10 days away from
work. His doctor feels that John
never fully recovered from the injury
he sustained in 2009.
OSHA Recordkeeping Scenario 20
 New Cases
 You must consider an injury or illness to
be a "new case" if: The employee has not
previously experienced a recorded injury
or illness of the same type that affects
the same part of the body, or The
employee previously experienced a
recorded injury or illness of the same
type that affected the same part of the
body but had recovered completely (all
signs and symptoms had disappeared).
OSHA Recordkeeping Scenario 21
 Pete
Lizza, a machinist, pulled a
muscle in his left arm in the turbomachinery department while lifting a
part. The injury occurred on Friday,
June 7 at 1:32 pm. Pete went to see
the doctor and no medical treatment
was recommended. The next week
was a scheduled plant shut down.
Pete returned to work the Monday
following the plant shut down.
OSHA Recordkeeping Scenario 21
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You need to record a case of this type
only if you receive information from a
physician or other licensed health care
professional indicating that the
employee should not have worked, or
should have performed only restricted
work, during the scheduled time off. If
so, you must record the injury or illness
as a case with days away from work or
restricted work, and enter the day
counts, as appropriate.
OSHA Recordkeeping Scenario 22
 Bill
Keegan, a landscaper, injured his
back in a customers yard picking up a
rock on Wednesday, June 12. Bill’s
doctor recommended that he take off
17 days of work and take a
prescription anti-inflammatory. Bill
had only worked for the landscaping
company for 1 day and had an
existing non-work related back injury.
OSHA Recordkeeping Scenario 22
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You must consider an injury or illness to
be work-related if an event or exposure
in the work environment either caused
or contributed to the resulting condition
or significantly aggravated a pre-existing
injury or illness. A preexisting injury or
illness has been significantly
aggravated, for purposes of OSHA injury
and illness recordkeeping, when an
event or exposure in the work
environment results in any of the
general recording criteria.
OSHA Recordkeeping Scenario 23
 Kaitlin
Fajt, a receptionist in the
customer service department, slipped
and fell on a wet floor injuring her
lower back on Wednesday, June 26.
Kaitlin’s PLHCP recommended that
she only work 4 hours each day for
the next 20 days. Kaitlin left for
another employment opportunity after
5 days.
OSHA Recordkeeping Scenario 23
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Yes, it is recordable but if the employee
leaves your company for some reason
unrelated to the injury or illness, such as
retirement, a plant closing, or to take
another job, you may stop counting days
away from work or days of restriction/job
transfer. If the employee leaves your
company because of the injury or
illness, you must estimate the total
number of days away or days of
restriction/job transfer and enter the day
count on the 300 Log.
OSHA Recordkeeping Scenario 24
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Angelo Polich, a machinist in the
processing department, was stung by a
bee in the mouth while taking aspirin for
an non-work related condition with a
drink that he had purchased off site
while at lunch at 1:47pm on Monday
July 15, 2012. Angelo is allergic to bee
stings and had to be hospitalized.
Angelo missed 20 days and then
returned to work at full duty.
OSHA Recordkeeping Scenario 24
If an injury/illness results from an event or exposure in the work
environment, work-relatedness is “presumed” Exemptions:
1.
Occurs when the employee is present in the work environment
as a member of the general public
2.
Results solely from voluntary participation in a wellness program,
or in a medical, fitness, or recreational activity
3.
Involves signs and symptoms that surface at work, but result
solely from a non-work-related event or exposure
4.
Is solely the result of an employee eating, drinking, or preparing
food or drink for personal consumption
5.
Is solely the result of an employee doing personal tasks at the
establishment outside of the employee’s assigned working hours
6.
Is solely the result of personal grooming, self-medication for a
non-work-related condition, or is intentionally self-inflicted
7.
Is caused by a vehicle accident and occurs on a company
parking lot or access road while the employee is commuting
8.
Is the common cold or flu
9.
Is a mental illness (unless specific situations apply)
OSHA Recordkeeping Scenario 25
 Andrew
Janick, a grinder operator, in
Department 8, lacerated his right
index finger using a grinder on
Tuesday, July 23. Andrew was sent
to the emergency room where the
wound was closed using adhesive
surgical glue. Stitches were not
necessary. Andrew returned to work
the next day with no work restrictions.
OSHA Recordkeeping Scenario 25
First Aid Treatments
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Non-prescription drugs in nonprescription strength
Administering a tetanus, (others
like Hep B and rabies are
recordable)
Cleaning, flushing or soaking
wounds on the surface of the skin
Using wound coverings such as
adhesive bandages, gauze pads,
etc., or using butterfly bandages
or steri-strips.
Using hot or cold therapy
Using non-rigid means of support,
such as elastic bandages, wraps,
non-rigid back belts, etc.
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Drilling of a fingernail or toenail or
draining a blister
Using an eye patch
Removing foreign body 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, or other simple means
Use of finger guards.
Using massages (physical therapy
and chiropractic treatment are
considered medical treatment.
Drinking fluids for relief of heat
stress.
OSHA Recordkeeping Scenario 26
 Greg
Evans, a surgical sales
representative, was killed in a car
accident when a dump truck traveling
in a construction zone at mile marker
81 on I-76 struck him broadside at
4:01pm on Thursday, July 25. Greg
was performing work duties at the
interest of his employer at that time
period.
OSHA Recordkeeping Scenario 26
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Within eight (8) hours after the death of any
employee from a work-related incident or the inpatient hospitalization of three or more employees
as a result of a work-related incident, you must
orally report the fatality/multiple hospitalization by
telephone or in person to the Area Office that is
nearest to the site of the incident. You may also
use 1-800-321-OSHA (1-800-321-6742).
You do not have to report all of these incidents. If
the motor vehicle accident occurs on a public
street or highway, and does not occur in a
construction work zone, you do not have to report
the incident to OSHA.
OSHA Recordkeeping Scenario 27
 John
Shuey, a warehouse material
handler, pulled his back out while
lifting boxes in the warehouse on
Thursday, September 12. John lifts
30 lb boxes all day long. John saw
that doctor and returned to work the
next day with restrictions. The doctor
recommended that John not lift
anything over 50 lbs for the next 2
weeks.
OSHA Recordkeeping Scenario 27
 A “Job
Restriction” occurs when,
because of the injury or illness, the
employer or a PLHCP keeps the
employee from performing one or
more of the “routine functions” of their
job, or from working the full work day
 A “Job Transfer” occurs when an
injured or ill employee is assigned to
a job other than his/her regular job
 An employee’s “routine functions” are
those work activities the employee
regularly performs at least once a
week.
OSHA Recordkeeping Scenario 28
 Jim
O’Brien, a lathe operator in the
machining department, dropped a
piece on his left foot and broke it on
Wednesday, October 23. Jim’s
PLHCP placed the foot in a cast and
recommended that he take some time
off. A specific amount of time was not
given and could not be obtained from
the PLHCP.
OSHA Recordkeeping Scenario 28
 If
the employee is out for an extended
period of time, you must enter an
estimate of the days that the
employee will be away, and update
the day count when the actual
number of days is known. Information
must be entered on the OSHA 300
Log within 7 calendar days.
OSHA Recordkeeping Scenario 29
 David
Reese, a manager in the
quality department, slipped and fell on
ice in the company parking lot on
Friday, November 8 on his way into
work in the morning. David broke his
right arm. David missed 4 days of
work and was placed on work
restrictions for 10 days.
OSHA Recordkeeping Scenario 29
 Injuries
that occur on a company
access road or parking area are
recordable if they meet the specific or
general recording criteria unless they
are the injury or illness is caused by a
motor vehicle accident.
OSHA Recordkeeping Scenario 30
 Jim
Poteka, a bouncer at a bar,
suffered a broken nose breaking up
an altercation in the bar lounge at
11:47pm on December 14. Jim
received 7 stitches and his doctor
recommended he take approximately
60 days off of work for the nose to
heal. This amount of time off means
that Jim will be off well into the
following year.
OSHA Recordkeeping Scenario 30

It is recordable but you only record the injury
or illness once. You must enter the number
of calendar days away for the injury or illness
on the OSHA 300 Log for the year in which
the injury or illness occurred. If the employee
is still away from work because of the injury
or illness when you prepare the annual
summary, estimate the total number of
calendar days you expect the employee to
be away from work, use this number to
calculate the total for the annual summary,
and then update the initial log entry later
when the day count is known or reaches the
180-day cap.