Transcript Slide 1

OSHA Recordkeeping
Compliance Update
Jo Beth Cholmondeley
Regional Safety Engineer
Doug Fletcher
Compliance Assistant Specialist
VPPPA
Topics
• Most Common Recordkeeping Deficiencies at
VPP sites
• OSHA’s NEP on Recordkeeping
• New Developments
– Update on MSD Column
– Modernization of Data Collection Process
Comment Period
• IF time:
– Metric
– Review
Most Common Deficiencies
Recordkeeping
1904.30 – Multiple
Business Establishments
• Contractors
– Can keep records at central location
– Must keep a separate OSHA Form 300 for each
establishment that is expected to be in operation
for more than a year
• Common Deficiency
– Contractor do not keep separate log and separate
hours at VPP sites
Common Deficiencies
• Calculation of DART
– Days Away & Restricted (column H & I) X
200,000 / Total Hours Worked
– Information that goes on the yearly report
– Will be recalculated at the audit
• More than one 
• Quick Check
– Total in Column G-J equals Column M
x
x
Confusion
• Work compensation vs. OSHA
recordable
• Parking Lots
• Quit or Fired
• Your Questions
1904.5 – Exceptions
• Present as a member of the general public
• Symptoms arising in work environment that are
solely due to non-work-related event or exposure
(Regardless of where signs or symptoms surface, a
case is work-related only if a work event or exposure
is a discernable cause of the injury or illness or of a
significant aggravation to a pre-existing condition.)
• Voluntary participation in wellness program, medical,
fitness or recreational activity
• Eating, drinking or preparing food or drink for
personal consumption
1904.5 – Exceptions
• Personal tasks outside assigned working hours
• Personal grooming, self medication for non-workrelated condition, or intentionally self-inflicted
• Motor vehicle accident in parking lot/access
road during commute not on clock
• Common cold or flu
• Mental illness, unless employee voluntarily
provides a medical opinion health care
professional (PLHCP) having appropriate
qualifications and experience that affirms workrelatedness
RECORDKEEPING
National Emphasis Program
NEP
VPP sites are exempt
OSHA’s Recordkeeping NEP
• National Emphasis Program (NEP)
– Response to criticism from GAO audit
• Employer’s not keeping accurate records
– Records re-creation / verification inspections to be
scheduled
• Both GI and Construction sector
– Very resource intensive inspection Process
• Special software
• All employer records reviewed to “catch” data
• Intensive employee interview process
OSHA’s Recordkeeping NEP
• Results so far
– Switching of K & L columns
• Still using old form
– Some under recording
– Expansion into other inspections
• Ergo
• Machine Guarding
– Resource intensive
• CPL expanded to 2 years.
Common Citations
1904.32 – Annual Summary
• Review OSHA Form 300 for
completeness and accuracy,
correct deficiencies
• Complete OSHA Form 300A
• Certify summary
• Post summary
1904.33 – Retention
and Updating
• Retain forms for 5 years following the year
that they cover
• Update the OSHA Form 300 during that
period
• Need not update the OSHA Form 300A or
OSHA Form 301
New Developments
• Addition Musculoskeletal
Disorder (MSD) Column
• Modernization of Collection
Process Comments Requested
Musculoskeletal Disorder
Column
MSD Column History
– January 1, 2002 Final Rule published with comments
requested on MSD column
– June 30, 2003, OSHA has decided MSD’s captured
without a separate column for musculoskeletal disorders
(MSD) (1904.12 vacated)
– Still must record work-related injuries and illnesses
involving muscles, nerves, tendons, ligaments, joints,
cartilage and spinal discs in accordance with the
requirements applicable to any injury or illness
– On the OSHA 300 log, check either the entry for “injury”
or “all other illnesses”
Present
• Addition MSD Column to Log
– Comment Period Closed
– Changes going forward
• Fairly certain that MSD column will be
added to log
– Recording Criteria ?
– Out Soon
• Effective date?
Comment Period for Modernization of
OSHA’s Injury & Illness
Data Collection Process
(Electronic)
Comments must be submitted
by June 18, 2010
Comment Period for Modernization of
OSHA’s Injury & Illness Data Collection
Process (Electronic)
• Informal stakeholder meetings
– First meeting today in DC
– Chicago, IL - June 3
• Written Comment submitted by June 18, 2010
• Comments submitted
– Electronically (OSHA website)
– Faxed, mailed or courier
Issues
Collection of Electronic Data
• Open Government Initiative
– Ability of public to get information
• OSHA Date Initiative (ODI)
– Currently provides only summary data
– Data 3 yrs old when released
• BLS Data
– Data for industry but not for specific
establishments
Topics
Collection of Electronic
Recordkeeping Data
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Scope of data collected
Use of Data collected
Methods of data collection
Economic impacts
Additional topics
Questions
• What data should the system collect?
• Linking data to other sources?
– medical records, work compensation…
• Collect data from every employer?
• What purpose would it serve to OSHA and
others
• How data be used to make national or sector
specific estimates?
Questions Continued
• Strengths and limitations of collected data
• Would publishing data indicating # of ee’s and
ee’s hours disclose confidential commercial or
trade secret information?
• How can OSHA others experience be used in
developing program
• How to design effective quality assurance
program for data entered?
• How often should data be collected?
Questions continued
• How to design effective quality assurance
program for data entered?
• How often should data be collected?
• What training and outreach will be necessary?
• How ensure that small business employers are
able to comply?
• What analytical tools developed?
• How can OSHA improve the accuracy of
recordkeeping data?
Your Questions?
Jo Beth Cholmondeley
Regional Safety Engineer
Regional Recordkeeping Coordinator
(816) 283-0545 ext. 265
[email protected]
More Information
• OSHA Website
– www.osha.gov (left column Recordkeeping)
– CPL 02-00-135
– OSHA Recordkeeping Handbook
• OSHA 3245-09R 2005
– Latest interpretations
Safety and Health Management
Performance Metrics
How The OSHA-300 Data Should Be
Used
• Accident trends
• Accident rates: (rate per 100 employee years)
– {(# cases) X (200,000)} / (# hours worked) = rate
• Accident demographics
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Source of hazard
Type injury/illness
Victim demographics
Body part affected
BLS Model
Hazardous
conditions/practices
Tailoring Safety and Health
Metrics to Your Organization
STEP 1:
STEP 2:
STEP 3:
Perception
Survey
Incident
Data
Management
System
Audit Findings
Analyze Results
Management System Drivers
ACTIVE LEADERSHIP

EXPECTATIONS AND INVOLVEMENT
STEP 4:
Behavioral
Observation
Data
EMPLOYEE INVOLVEMENT
PLANNING FOR SAFE CONDITIONS
GOAL SETTING AND
ACTION PLANNING
EMPLOYEE ACCOUNTABILITY
COMMUNICATIO NS
HAZARD IDENTIFICATION AND
ELIMINATION, AND SAFE PRACTICES
INCIDENT INVESTIGATION
TRAINING AND
EDUCATION
BEHAVIORAL FEEDBACK
Successful Safety Management
HSE Performance over time
Technology
and standards
HSE
Incident rate
Management
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Behaviour
Visible leadership / personal accountability
Shared purpose & belief
Aligned performance commitment & external
view
• HSE delivers business value
Systems
Engineering improvements
Hardware improvements
Safety emphasis
E&H Compliance
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Time
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Integrated HSE-MS
Reporting
Assurance
Competence
Risk Management
Improved
culture
Questions?
Jo Beth Cholmondeley
Regional Safety Engineer
Regional Recordkeeping Coordinator
(816) 283-0545 ext. 265
[email protected]