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OSHA Recordkeeping
CONN-OSHA Breakfast
Roundtable Discussion Group
January 20, 2015
Purpose of Recordkeeping
• To require employers to record and report workrelated fatalities, injuries and illnesses
• OSHA injury and illness recordkeeping and Workers’
Compensation are independent of each other
• Does not mean
• The employer or employee was at fault
• An OSHA rule has been violated,
• The employee is eligible for workers’ compensation
Remember, OSHA rules and regulations are
2
made with the worst employers in mind.
Partial Exemptions for Private Sector
1904.1 Small employer (10 or less)
1904.2 Industry
Now listed by NAICS
(North American Industry Classification System)
Effective January 2015, the list of exempt
industries has changed.
1904.3 Other Federal agencies
OSHA Records: Government
Upon request, you have 4 business hours to
provide government representatives copies of
– OSHA 300 Log
– OSHA 300A Summary
– OSHA 301 Incident Report
– Confidential listing of privacy concern
cases, including names of the employees
Requirements for ALL Employers
1904.39 Report fatalities with 8 hours
Within 24 hours report:
• amputations
• the loss of an eye
• in-patient hospitalization of an employee
1904.41-Annual OSHA injury and illness survey
(if selected by OSHA)
1904.42-BLS Annual Survey of Occupational Injuries
and Illnesses (if selected by BLS)
OSHA Records: Employee Access
• Post the OSHA Summary Form 300A at
worksite from February 1st through April 30th.
• Upon employee request, you have until the end
of the next business day to provide:
– Copies of OSHA Forms 300 Log & 300A Summary
– His or her individual OSHA Form 301
• Includes requests from former employees and
personal or authorized representatives
First Aid Defined, 1 of 3
• Visits to a PLHCP* solely for observation or
counseling.
• Diagnostic procedures, such as x-rays and
blood tests, including the administration of
prescription medications solely for diagnostic
purposes (e.g., eye drops to dilate pupils).
• Using non-prescription medications at nonprescription strength (per box instructions).
• Administering tetanus immunizations.
• Cleaning, flushing or soaking wounds on the
surface of the skin.
* Physician or other Licensed Health Care Professional
First Aid Defined, 2 of 3
• Using wound coverings such as bandages,
Band-Aids, gauze pads, butterfly bandages,
Steri-Strips, and other similar coverings.
• Using any non-rigid means of support such as
elastic bandages, wraps, non-rigid back belts,
etc.
• Using temporary immobilization devices while
transporting an accident victim (e.g., splints,
slings, neck collars, back boards, etc.).
• Drilling of fingernail or toenail to relieve
pressure, or draining fluid from a blister.
First Aid Defined, 3 of 3
• Removing splinters or foreign material from
areas other than the eyes by irrigation,
tweezers, cotton swabs or other simple
means.
• Removing foreign bodies from the eye using
only irrigation or a cotton swab.
• Using eye patches or finger guards.
• Non-therapeutic massages (spa treatment).
• Using hot or cold therapy.
• Drinking fluids for relief of heat disorder.
Column H: Days Away from Work
• An injury or illness involving one or
more days away from work.
• Do not include the day of the injury or
onset of illness.
• A job restriction/transfer is
recommended, but if the employer
cannot accommodate this, the
employee stays home.
Column I: Job Transfer or Restriction
• Record cases with days of job transfer or
restriction but absolutely no days away
from work.
• Do not include the day of injury or onset of
illness.
• If a restriction or transfer is recommended,
but such work is not available and the
employee stays home, the case is counted
in Column H: Days Away from Work.
Cases with Days Away AND
Job Transfer or Restriction
• Record the case ONCE AND ONLY ONCE
in Column H. Leave Column I blank.
• This is true even if the number of job
transfer/restriction days is greater than
the number of days away from work.
• Record the number of days away in
Column K and the number of
transfer/restriction days in Column L.
Example: Rob is out of work for 2 days and
on restricted duty for 10 days.
X
2
10
Remember…
• If a case is limited to First Aid treatment
and there is no lost time - days away
from work or job transfer/restriction –
it is not recordable.
• This is true even if the First Aid
treatment is administered at a health
clinic, emergency room, hospital, or
other medical treatment facility.
Are these cases recordable?
Yes
No
Yes
• Susan falls in the parking lot. Her right leg
is heavily bruised and she stays at home
the next day to recover. No medical
treatment.
• Carl trips at work, hurting his ankle. He
goes to the emergency room for an X-ray,
which shows the ankle is not broken, and
returns to work the next day.
• Peter cuts his finger at work, receives
stitches at the walk-in clinic, and
immediately returns to work.
Column M: Injury and Illness Type
• For every recordable case, there
must be a check mark in an injury or
illness category.
• The total number of cases
(G+H+I+J) MUST equal the total for
Column M (1+2+3+4+5+6).
OSHA 300A Summary
Total of 6 cases
0
3
1
10
2
=
2
4
1
1
Total of 6 injuries
and illnesses
Employment & Hours
Total Hours ÷ Average # Employees ÷ 50
weeks =
Average number of hours worked per
week per employee.
OSHA 300A Summary
Hair Club for Men
516 Blueberry Lane
Manchester
CT
06040
Hair Replacement Services
7299
812199
80
160,000
Sy Sperling
860 555-2343
President & Client
01/20/2014
160,000 ÷ 80 ÷ 50 = 40 hours
per week
per person
Bloodborne Pathogens
• Record all work-related needlesticks and cuts
from sharp objects that are contaminated with
another person’s blood or other potentially
infectious material
• Record splashes or other exposures to blood or
other potentially infectious material if it results
in a diagnosis of a bloodborne disease or meets
the general recording criteria
DART Rate
• Days Away, Restricted, or Transferred
• Indicates how many days away,
restriction, or transfer cases occur per
100 full-time workers.
• Calculated using the information on the
OSHA Form 300A
• Used by Federal OSHA to identify
companies with DART rates above the
national average.
DART Rate Formula
(Columns H + I) x 200,000
Total Hours Worked
U.S. DART Rate 1.8
Private 1.7
Public 2.3
CT DART Rate 2.3
Private 2.1
Public 3.5
(Days away, Restricted, or Transferred
cases per 100 full-time workers)
TRC Rate
• Total Recordable Cases
• Indicates how many non-fatal
recordable cases occur per 100 fulltime workers.
• Calculated using the information on
the OSHA Form 300A.
TRC Rate Formula
(Columns H+I+J) x 200,000
Total Hours Worked
U.S. TRC Rate 3.5
Private 1.8
Public 5.2
CT TRC Rate 4.1
Private 2.1
Public 6.9
(Recordable cases per 100 full-time workers)
Resources
• U.S. OSHA www.osha.gov
• Incidence Rate Calculator and Comparison Tool
http://data.bls.gov/IIRC/calculate.do
• North American Industry Classification System
www.naics.org
• Connecticut Department of Labor www.ct.gov/dol
• Workers’ Comp First Report of Injury form
http://wcc.state.ct.us/download/acrobat/fri.pdf
• Joanne Regan – OSHA, [email protected], 617565-9856
OSHA Recordkeeping
Questions???