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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 • • • • • 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 – – – – 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 • • • • 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 • • • • • Time • • • • 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]