Recordkeeping_3.ppt
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Recordkeeping &
Reporting: How the
Revised Standard
Affects Industry
History of the Regulations
In place since 1971
Proposed changes announced in February
1996 (“The Revision of the Injury & Illness
Recordkeeping System”)
Revision announced on January 18, 2001
Final rule published in Federal Register on
January 19, 2001
Final rule effective January 1, 2002
What are the regulatory
requirements?
OSHA regulations address:
Occupational injury and illness
recording
Occupational injury and illness
reporting
Applicable regulations:
29 CFR 1904
29 CFR 1952
What is the purpose of the
regulations?
Provide employers with a tool for tracking
and recording workplace illnesses and
injuries
Aid employers with recognizing workplace
hazards and correcting hazardous
conditions
Allow OSHA to track trends in safety
What prompted revisions to the
regulations?
Industry complaints
Former recordkeeping requirements were
complicated
Former recordkeeping forms were
cumbersome
Confusing regulations
Former regulations included only
requirements
Interpretations were found in many forms
What prompted revisions to the
regulations? (continued)
Former regulations did not include
provisions for needlestick and sharps
injuries
Former regulations included complicated
criteria for reporting musculoskeletal
disorders (MSDs)
OSHA attempting to revise, update, and
simplify all regulations
Who is subject to the
regulations?
All employers subject to the OSH Act
Exempt from most requirements: Industries
classified as low-hazard sectors
e.g., Retail, service, finance, insurance, and real estate
List revised to reflect recent industry illness/injury data.
Excluded from full reporting requirements:
Religious establishments
Household employees performing ordinary domestic
tasks
Certain volunteers
Who is subject to the
regulations? (continued)
Excluded from full reporting requirements:
(continued)
Industries classified under SIC codes 52-809,
except codes 52-54, 70, 75, 76, 79, and 80
Small businesses (10 or less employees)
Sheltered workshops and job training programs
(unless personnel are compensated)
Stockholders (unless employed by the corporation
in which they hold stock)
Self-employed persons
Primary Improvements to the
Standard
Better definition of work-related injuries
Clarified definition of restricted work
Provisions for improved employee
awareness and involvement
Provides workers or their representatives
access to the information on recordkeeping
forms
Increases awareness of potential hazards in
the workplace
Provisions for employee privacy
Primary Improvements to the
Standard (continued)
“Plain English” wording
Question and answer format
Inclusion of checklists and flowcharts
Inclusion of interpretations as well as
requirements
Simpler forms
Flexibility for using computers to meet
requirements
Summary of Key Provisions to
New Recordkeeping Rule
Updated recordkeeping forms
OSHA Form 300: Log of Work-related Injuries
and Illnesses
Replaces Form 200: Log and Summary of
Occupational Injuries & Illnesses
Simplified reporting requirements
Printed on smaller legal sized paper
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Updated recordkeeping forms (continued)
OSHA Form 301: Injury and Illness Incident
Report
Replaces Form 101: Supplementary Record of
Occupational Injuries & Illnesses
Includes more data about how injury or illness
occurred
OSHA Form 300A: Summary of Work-related
Injuries and Illnesses (easier calculation of
incident rates)
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Eliminates different criteria for recording
work-related injuries and work-related
illnesses
New rule uses one set of criteria for injuries
and illnesses.
Former rule required employers to record all
illnesses, regardless of severity.
New rule accounts for severity of illness.
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Requires records to include any workrelated injury or illness resulting in:
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
licensed health care professional
Note: Exposures in and of themselves are not
recordable.
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Includes new definitions to simplify
recording decisions
Medical treatment
First aid
Restricted work
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Requires a significant degree of workrelated aggravation before a pre-existing
injury or illness becomes recordable
Includes separate provisions describing
recording criteria for cases involving
work-related transmission of tuberculosis
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Add additional exemptions to the
definition of work-relationship
Limits recording of cases involving
eating/drinking food beverages
Limits recording of common colds and flu
Limits recording of blood donations
Limits recording of exercise programs
Limits recording of mental illness
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Clarifies recording of “light duty” or
“restricted work” cases
Requires employers to record cases when
injured/ill employee is restricted from normal
duties
Defines normal duties: duties the employee
performs at least once weekly
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Conforms with new ergonomics standard
Requires employees to record all needlestick
and sharps injuries involving contamination
by another person’s blood or body fluids
Applies same recording criteria to MSDs as to
all other injuries and illnesses
Revised recordkeeping forms have separate
column for recording MSDs
Employers retain flexibility to determine
whether an event or exposure in work
environment caused or contributed to MSD
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Requires employers to record standard
threshold shifts (STS) in employees’
hearing
Defines STS: an adverse change in an
employee’s hearing threshold, relative to
his/her most recent audiogram
Requires recording hearing loss cases at 10
dB shift, rather than 25 dB shift
Provides a separate column on Form 300 to
capture statistics on hearing loss
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Changes regarding lost/restricted work
Change in terminology
Eliminates “lost workdays”
Focuses on “days away” or “days restricted or
transferred”
Includes new regulations for counting days
Rely on calendar days instead of workdays
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Changes to employer requirements
Employers must establish procedure for
employees to report injuries and illnesses
Employers must tell employees how to report
Employers are prohibited from discriminating
against employees who report
With change of ownership, seller must turn
over OSHA records to buyer
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Changes to employee rights
Privacy rights
Prohibits employers from entering an individual
employee’s name on Form 300 for certain types of
injuries/illnesses
Sexual assaults
HIV infections
Mental illness
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Changes to employee rights (continued)
Privacy rights
Provides employers the right not to describe the
nature of sensitive injuries where the employee’s
identity would be known
Gives employee access to portions of Form 301
relevant to the employee they represent
Requires employers to remove employees’ names
before providing data to persons not provided
access under the rule
Summary of Key Provisions to
New Recordkeeping Rule (continued)
Requires the annual summary to be
posted for three months (Feb. 1 to April
30) instead of one
Requires certification of annual summary
by a company executive
Changes reporting of fatalities and
catastrophes to exclude some motor
carrier and motor vehicle incidents
Allows all forms to be kept on computer
equipment or at alternate location
General Impact of Changes
Final rule anticipated to impact
approximately 1.3 million establishments
Some changes will increase number of
recordable cases; some will decrease number
OSHA anticipates roughly same number of
reported injuries/illnesses
Newly exempt industries will experience
reduced costs
General Impact of
Changes (continued)
Newly covered industries will experience
additional costs and benefits
Must learn new requirements
Must revise computer systems used for
recordkeeping
Areas of Potential Cost Savings
Form 300: Less time to complete simpler
forms
Exemptions from the requirement to
consider certain cases work-related (will
result in less cases being recorded)
Elimination of different recording criteria
for injuries and illnesses (will result in less
cases being recorded)
Areas of Potential
Cost Savings (continued)
Changes to the requirements for recording
illnesses and injuries with days away or
job restriction/job transfer (will result in
less cases being recorded)
Changes to the criteria for recording cases
of tuberculosis (will result in less cases
being recorded)
Changes to the criteria for recording
fatality/catastrophe incidents (will result in
less cases being recorded)
Areas of Potential
Cost Savings (continued)
Elimination of separate recording criteria
for MSDs (will result in less cases being
recorded)
Improvement in determining recordability
of illness/injury
Allowance of computerized and
centralized records
Areas of Potential Cost Increases
Form 300A
Requires increased employer review of data
and additional data on the average
employment/hours worked at establishment
Changes result in higher quality data, but
more time and cost to employer
Changes to the definitions of medical
treatment and first aid (will result in more
cases being recorded)
Areas of Potential
Cost Increases (continued)
Change to the criteria for recording cases
of hearing loss (will result in more cases
being recorded)
Change to the criteria for recording
needlestick and sharps injury (will result
in more cases being recorded)
Increased employee involvement
Employee privacy protections
Benefits of the Revised
Regulations
More accurate data regarding
occupational illnesses and injuries
Simplified overall recordkeeping systems
for employers
Better protection for employees’ privacy
“The revision… will not lessen an employer’s
recordkeeping responsibilities, but it will make it
easier to successfully meet the requirements.” —
Sec. of Labor, Alexis Herman
Resources for Additional
Information
Web site: www.osha.gov
OSHA Region IV (Alabama, Florida, Georgia,
Mississippi): 404-562-2300
29 CFR 1904: Occupational Injury and Illness
Recording and Reporting Requirements
“The Blue Book”: Recordkeeping Guidelines for
Occupational Injuries and Illnesses
Available from OSHA
Last updated in 1991