Transcript OSHA Recordkeeping - Indiana University of Pennsylvania

OSHA RECORDKEEPING REQUIREMENTS
Revised Recordkeeping rule effective on January
1, 2002
 Updates three recordkeeping forms

OSHA Form 300 – Log of Work-Related Injuries and
Illnesses
 OSHA Form 301 – Injury and Illness Incident Report
 OSHA Form 300A – Summary of Work-Related
Injuries and Illnesses

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1904.29
2
OSHA Form 300
3
OSHA Form 301
4
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
 Letter
of interpretation on reporting dates
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1904.4
RECORDING CRITERIA DECISION
TREE
NO
D id the e mploye e e xpe rie nc e a n
injury or illne s s ?
YES
NO
Is the injury or
illne s s w ork-re la te d?
YES
NO
Is the injury
or illne s s a ne w c a s e ?
U pda te the pre vious ly
re c orde d injury or illne s s
e ntry if ne c e s s a ry.
YES
NO
D o not re c ord the
injury or illne s s
D oe s the injury or illne s s me e t
the ge ne ra l re c ording c rite ria
or the a pplic a tion to s pe c ific c a s e s ?
YES
R e c ord the
injury or illne s s
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1904.4
WORK-RELATEDNESS

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

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1904.5
WORK-RELATEDNESS
 Work-relatedness
is presumed for injuries
and illnesses resulting from events or
exposures occurring in the work
environment
 A case is presumed work-related if, and
only if, an event or exposure in the work
environment is a discernible cause of the
injury or illness or of a significant
aggravation to a pre-existing condition.
The work event or exposure need only be
one of the discernible causes; it need not
be the sole or predominant cause
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WORK-RELATED EXCEPTIONS

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

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1904.5(b)(2)
GENERAL RECORDING CRITERIA
 Requires
records to include any workrelated injury or illness resulting in one of
the following:






Death
Days away from work
Restricted work or transfer to another job
Medical treatment beyond first aid
Loss of consciousness
Diagnosis of a significant injury/illness by a
physician or other licensed health care
professional
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1904.7(a)
GENERAL RECORDING CRITERIA
(CONTINUED)
Includes new definitions of medical treatment
and first aid to simplify recording decisions
 Clarifies the recording of “light duty” or
restricted work cases
 Letter of Interpretation on Temporary Employees

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1904.7(b)(5)
RECORDING NEEDLESTICKS
 Requires
employers to record all
needlestick and sharps injuries involving
contamination by another person’s blood
or other potentially infectious material
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1904.8
HEARING LOSS

Starting January 1, 2003, record all work-related hearing
loss cases where:
 Employee has experienced a Standard Threshold Shift
(STS)1, and
 Employee’s total hearing level is 25 decibels (dB) or
more above audiometric zero [averaged at 2000, 3000,
and 4000 hertz (Hz)] in the same ears as the STS
A STS is defined in OSHA’s noise standard at 29 CFR
1910.95(g)(10)(i) as a change in hearing threshold,
relative to the baseline audiogram, of an average of 10 dB
or more at 2000, 3000, and 4000 Hz in one or both ears.
 1
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MUSCULOSKELETAL DISORDERS
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

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TUBERCULOSIS & MEDICAL REMOVAL
 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
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1904.11 & 1904.9
ACCIDENT SCENARIOS
Scenario 1:

An employee drives into the company parking lot at 7:30 a.m., exits his car, and proceeds to cross the parking lot to
clock-in to work. A second employee, also on the way to work, approaches the first employee, and the two
individuals get into a physical altercation in the parking lot. The first employee breaks an arm during the
altercation. The employee goes to the doctor and receives medical treatment for his injury.

Company Response: The company deems this non-work related, and therefore non-recordable, since the
employees had not yet reported to work and a work task was not being performed at the time of the altercation.

OSHA Response: The recordkeeping regulation contains no general exception for purposes of determining workrelationship for cases involving acts of violence in the work environment. Company parking lots/access roads are
part of the employer's premises and therefore part of the employer's establishment. Whether the employee had not
clocked in to work does not affect the outcome for determining work-relatedness. The case is recordable on the
OSHA log, because the injury meets the general recording criteria contained in Section 1904.7.
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ACCIDENT SCENARIOS
Scenario 2:

An employee reports to work. Several hours later, the employee goes outside for a "smoke break." The
employee slips on the ice and injures his back.

Company Response: Since the employee was not performing a task related to the employee's
work, the company has deemed this incident non-work related and therefore not recordable.

OSHA Response: Under Section 1904.5(b)(2)(v), an injury or illness is not work-related if it is
solely the result of an employee doing personal tasks (unrelated to their employment) at the
establishment outside of the employee's assigned working hours. In order for this exception to apply, the
case must meet both of the stated conditions. The exception does not apply here because the injury or
illness occurred within normal working hours. Therefore, your case in question is work-related, and if it
meets the general recording criteria under Section 1904.7 the case must be recorded.
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COUNTING DAYS
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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1904.7(b)(3)
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
1904.35 & 36
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EMPLOYEE PRIVACY
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


Letter of Interpretation
1904.29(b)
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ANNUAL SUMMARY
 Requires
the annual summary to be
posted for three months instead of one
 Requires certification of the summary by a
company executive
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1904.32
REPORTING TO OSHA




Reporting of fatalities and catastrophes to exclude some
public transportation and motor vehicle accidents
All employers must still comply with OSHA standards,
display the OSHA poster, and report to OSHA within 8
hours:
 Any accident that results in one or more fatalities or
 The hospitalization of three or more employees.
Orally report the fatality/multiple hospitalization by
telephone or in person to the Area Office of the
Occupational Safety and Health Administration (OSHA).
Letter of Interpretation on the recordability of motor
vehicle accidents!
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1904.39
HAZARD COMMUNICATION

1926.59
 Identical to 1910.1200
 Adoption of GHS criteria, labeling, SDS, etc.
 Conduct chemical inventory
 Collect MSDS’s
 Identify chemicals/materials that fall under OSHA’s Hazard
Communication Standard
 Physical Hazard
 Health Hazard
 Toxic
 Carcinogenic
 Written program
 Employee Training
 Labeling
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