Safety Issue: OSHA requires most employers to maintain. Recording and Reporting Occupational Injuries and Illnesses

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1 Overview Safety Issue: Is your organization currently in compliance with OSHA s occupational injury and illness recording and reporting requirements? OSHA requires most employers to maintain occupational injury and illness records. The forms include the OSHA 300 log, the OSHA 301 Incident Report, and the OSHA 300-A Annual Summary form. Employers with 10 or fewer employees are exempt from most requirements of the recordkeeping rule, as are a number of industries classified as low-hazard retail, service, finance, insurance, and real estate sectors. However, all employers, no matter the size or classification, are still required to report work-related fatalities and multiple hospitalizations (three or more employees) within 8 hours by telephone or in person to OSHA. And covered employers who fail to keep up-to-date, accurate records of occupational injuries and illnesses may find themselves facing an OSHA citation and fines of up to $10,000. Legal Issues OSHA regulation: 29 CFR 1904 What injuries and illnesses must be recorded? An injury or illness must be recorded if it: Involves an employee. Is work-related. Is a new case (meaning that the employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body or that the employee previously experienced such an injury or illness but completely recovered). Federal OSHA does not require employers to record injuries that only require first aid on OSHA injury and illness forms. At most workplaces, injuries or illnesses requiring only first aid are commonplace. However, it is easy to get confused about when to record an incident and what is really a recordable event. A case is OSHA recordable if it involved treatment beyond first aid or a diagnosis of significant injury or illness. If a case is limited to first-aid treatment and there are no days away from work, job transfer, or job restriction, do not include the case on your OSHA 300 Log. The case is not OSHA recordable, even if the first-aid treatment is administered at a health clinic, emergency room, hospital, or other medical treatment facility. First-aid treatment is defined as: Visits to a physician or a licensed healthcare professional (PLHCP) solely for observation or counseling; 645-1

2 Overview Diagnostic procedures, such as X-rays and blood tests, including the administration of prescription medications solely for diagnostic purposes (such as eye drops to dilate pupils); Using nonprescription medications at nonprescription strength (per packaging instructions); Cleaning and flushing or soaking wounds on the surface of the skin; Using wound coverings, such as bandages, Band-Aids, gauze pads, butterfly bandages, Steri-strips, and other similar coverings; (Note: Wound-closing devices are medical treatment.) Using any nonrigid means of support, elastic bandages, wraps, or nonrigid back belts; Using temporary immobilization devices while transporting a victim, such as splints, slings, neck collars, and back boards; Drilling of fingernail or toenail to relieve pressure, or draining fluid from a blister; Removing splinters or foreign material from areas other than the eyes by irrigation, tweezers, a cotton swab, or other means; Removing foreign bodies from the eye using only irrigation or a cotton swab; Using eye patches or finger guards; Nontherapeutic massages (spa treatments); Using hot or cold therapy; Drinking fluids for relief of heat disorder; and Administering tetanus immunizations. When is an injury or illness considered work-related? An injury or illness is considered work-related if an event or exposure in the work environment caused or contributed to the condition or significantly aggravated a preexisting condition. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the workplace, unless an exception specifically applies. See 29 CFR (b)(2) for the exceptions. The work environment includes the establishment and other locations where one or more employees are working or are present as a condition of their employment. See 29 CFR (b)(1). Which work-related injuries and illnesses should you record? Record those work-related injuries and illnesses that result in: Death Loss of consciousness Days away from work Restricted work activity or job transfer Medical treatment beyond first aid You must record any significant work-related injury or illness that is diagnosed by a physician or other licensed health care professional. You must record any work-related case involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum. See 29 CFR What are the additional criteria? You must record the following conditions when they are work-related: 645-2

3 Overview Any needlestick injury or cut from a sharp object that is contaminated with another person s blood or other potentially infectious material Any case requiring an employee to be medically removed under the requirements of an OSHA health standard Tuberculosis infection as evidenced by a positive skin test or diagnosis by a physician or other licensed health care professional after exposure to a known case of active tuberculosis An employee s hearing test (audiogram) reveals: 1. That the employee has experienced a Standard Threshold Shift (STS) in hearing (an average of 10 decibels (db) or more averaged at 2000, 3000, and 4000 Hz) in one or both ears; and 2. The employee s total hearing level is 25 db or more above audiometric zero (also averaged at 2000, 3000, and 4000 Hz) in the same ear(s) as the STS. How do you calculate the formulas for injury and illness incidence rates? Total # of injuries and illnesses x 200,000 = # of hours worked by all employees TOTAL RECORDABLE CASE RATE # of entries in Column H + Column I x 200,000 = # of hours worked by all employees DART INCIDENCE RATE Management Issues There are many important management issues involved in meeting the requirements of OSHA s recording and reporting standard. You must: Determine if an incident needs to be recorded. First you must decide whether a recordable incident has occurred according to the various criteria of the standard. If so, then the injury or illness must be recorded. Add the incident to the OSHA 300 Log. Fill in the date relating to the incident on the 300 Log, making sure that all the required information is provided. Injuries and illnesses must be entered within 7 calendar days of your becoming aware of the incident. If there is a privacy issue involved in the case, remember to enter privacy case instead of the employee s name, and keep a separate confidential list with the employee s name. Complete the OSHA 301 Incident Report. An incident report should be completed at the same time the injury or illness is entered into the OSHA 300 Log. However, OSHA allows you to substitute an insurance form for this incident report as long as the insurance form contains the same information in a readable and understandable format and is completed using the instructions for the OSHA 301 Incident Report. Retain and update records as required. Remember that if you have many different facilities, you must maintain a separate OSHA 300 Log for each establishment. All injury and illness records must be retained for 5 years following the end of the calendar year covered by these records

4 Overview If during the 5-year period there is a change in the extent or outcome of an injury or illness that affects an entry on a previous year s OSHA 300 Log, then the first entry should be lined out and a corrected entry made on that log. You must be able to present records you are required to keep under Part 1904 to any authorized government representative within 4 business hours. Provide employees and their representative access to your records. You must provide employees with access to your records concerning occupational injuries and illnesses. When an employee or an employee representative asks to see the OSHA 300 Log or an OSHA 301 Incident Report, you must provide a copy by the end of the next business day. Prepare the annual summary and post it. At the end of each calendar year, you must summarize the information on your OSHA 300 Log by totaling the column entries on the log and entering this information on the OSHA 300-A, the annual summary form. The annual summary must be certified by a company executive and signed and dated by the preparer. This form must be posted between February 1 and April 30 of the year following the year covered by the summary in a conspicuous place where all employees can see it (for example, on the employee bulletin board where you have posted your OSHA Job Safety and Health Protection poster). Complete and return annual survey forms. Both OSHA and the Bureau of Labor Statistics (BLS) send out survey forms annually to some employers. If you receive one of these surveys, you must fill it out and return it within 30 calendar days. Call OSHA directly within 8 hours of certain incidents. When an employee is killed on the job or when three or more employees are hospitalized because of a workplace incident, you must notify the OSHA area office nearest the location of the incident in person or by phone within 8 hours. You should be prepared to provide the agency with complete information about the incident at this time. Training Issues There are four main points to keep in mind concerning training to meet the requirements of OSHA s recording and reporting standard: Involve employees in the process. One of the specific revisions in the new recording and reporting standard is that OSHA wants employers to promote improved employee awareness and involvement in the recordkeeping process, providing workers and their representatives access to the information on recordkeeping forms and increasing awareness of potential hazards in the workplace. Train employees to report injuries and illnesses promptly. All employees should be encouraged to report all incidents immediately and thoroughly. They should know whom to report an incident to and what information to be prepared to give. Train supervisors to complete accident reports promptly and accurately. Supervisors play a key role in the maintenance of accurate and up-to-date injury and illness records. They should be trained to complete accident reports promptly 645-4

5 Overview and accurately. It is these reports that provide the basis for the information needed to complete the OSHA recording and reporting forms. Train employees responsible for maintaining OSHA recording and reporting forms to fulfill their duties completely and accurately. The employees who are responsible for filling out and updating the OSHA 300 Log, OSHA 301 Incident Reports, and the annual summary (300-A) must be well trained so that they understand all aspects of the regulations and are completely familiar with the various forms. This is the only way your records will be accurate and ready for inspection, should the need arise. Take Action Use the information in these checklists to make sure that you comply with OSHA s recording and reporting requirements. You can use the quiz that follows the checklists to test the knowledge of the people in your organization responsible for maintaining occupational injury and illness records involving the new requirements. For Further Help For more information about the regulations, contact the OSHA area office nearest you and ask for the recordkeeping coordinator, or check OSHA s website at where you can find the complete text of the regulation and the required recordkeeping forms, which you can download

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7 Date: Work Area: Inspected By: OSHA Compliance Checklist Occupational Injuries and Illnesses [29 CFR 1904] Subpart C Recordkeeping Forms and Reporting Criteria Do you keep records of each fatality, injury, and illness that is work related? [1904.4(a)(1)] Do you keep records of each fatality, injury, and illness that is a new case? [1904.6(a)(1),(2)] Do you record any work-related case involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum? [1904.7] Do you record all injuries and illnesses that result in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness? [1904.7(a)] Do you also record each significant injury and illness diagnosed by a physician or other licensed health care professional even if it does not result in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness? [1904.7(a)] Do you record an injury or illness that results in death by entering a check mark on the OSHA 300 Log in the appropriate space? [1904.7(b)(2)] Do you report any injury or illness that results in days away from work by entering a check mark on the OSHA 300 Log in the appropriate space and by entering the number of calendar days away from work in the days column? [1904.7(b)(3)] Do you enter an estimate of the days the employee will be away if it will be an extended period and then update the day count when the actual number of days is known? [1904.7(b)(3)] Do you report any injury or illness that results in restricted work or job transfer by entering a check mark on the OSHA 300 Log in the appropriate space and by entering the number of restricted or transferred days in the restricted workdays column? [1904.7(b)(4)] Do you record on OSHA Log 300 all workrelated needlestick injuries and cuts from sharp objects that are contaminated with another person s blood or other potentially infectious material? [1904.8(a)] Do you record on OSHA Log 300 any case where an employee is medically removed under the medical surveillance requirements of an OSHA standard? [1904.9(a)] Do you record all cases where an employee s hearing test reveals that a Standard Threshold Shift (STS) has occurred by checking the hearing loss column on OSHA Log 300? [ (a)] Continued 645-7

8 Continued Do you record all cases where an employee has been occupationally exposed to anyone with a known case of active tuberculosis and that employee subsequently develops TB? [ (a)] Do you enter a one or two line description of each recordable injury and illness on OSHA Log 300? [ (b)(1)] Do you summarize the information from the OSHA 300 Log on the OSHA 300-A form at the end of each year? [ (b)(1)] Do you complete an OSHA 301 Incident Report form (or equivalent) for each recordable injury or illness entered on the OSHA 300 Log? [ ((b)(2)] Do you enter each recordable incident on the OSHA 300 Log no later than 7 calendar days of receiving the information that a recordable injury or illness has occurred? [ (b)(3)] When you have a privacy concern case, do you omit the employee s name on the OSHA 300 Log and instead enter privacy case in the space normally used for the employee s name? [ (b)(6)] Do you then keep a separate, confidential list of the case numbers and employees names so that you can update the cases and provide the information to the government if asked to do so? [ (b)(6)] Subpart D Other OSHA Injury and Illness Recordkeeping Requirements If you have multiple business establishments, do you keep a separate OSHA 300 Log for each establishment that is expected to be in operation for 1 year or longer? [ (a)] Do you create an annual summary (OSHA form 300-A) of illnesses and injuries recorded on the OSHA 300 Log at the end of each calendar year, certify the summary, and post it in a conspicuous place where notices to employees are customarily posted? [ (b)(5)] Do you post the annual summary no later than February 1 of the year following the year covered by the records and keep the posting in place until April 30? [ (b)(6)] Do you retain the OSHA 300 Log, the OSHA 301 Incident Report forms, and a privacy case list (if one exists) for 5 years following the end of the calendar year that these records cover? [ (a)] Do you involve employees and their representatives in the recordkeeping system by informing employees of how they must report injuries or illnesses and by providing employees with access to your records? [ (a)(1),(2)] Do you provide a copy of the OSHA 300 Log or a 301 Incident Report to any employee or employee representative who requests a copy by the end of the next business day? [ (b)(2)(B)(iii),(v)] Subpart E Reporting Fatality, Injury, and Illness Information to the Government Do you report any work-related fatalities or multiple hospitalizations (three or more employees) within 8 hours of the incident by telephone ( ) or in person to the OSHA area office nearest the site of the incident? [ (a)] In these cases, are you prepared to provide OSHA with the name of the establishment, the location of the incident, the time of the incident, the number of fatalities or hospitalized employees, the names of any injured employees, a brief description of the incident, and the name and number of a contact person in your organization? [ (b)(2)] Continued

9 Continued If you receive OSHA s annual survey form, do you complete the form and return it to OSHA within 30 calendar days, or by the date stated in the survey form, whichever is later? [ (a),(b)(2)] If you receive a Survey of Occupational Injury and Illness survey form from BLS, do you promptly complete and return it? [ (a)] Corrective Action Completed (date): Supervisor: Routed to: 645-9

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11 Checklist Requirements Checklist YES NO OSHA 300 Log Have you entered a number that is unique for each case in Column A? Have you entered the employee s name in Column B? Have you specified the employee s regular job title in Column C? Have you entered the date of the injury or onset of the illness in Column D? Have you listed in Column E where the incident occurred? Have you briefly described in Column F the nature of the injury? Have you classified the case by checking only the most serious result for each case (death in Column G, days away from work in Column H, job transfer or restriction in Column I, or other recordable case in Column J)? Have you entered the number of days away from work in Column K? Have you entered the number of days of transfer or restriction in Column L? In Column M, have you checked the Injury box or have you checked a box for a particular type of injury? Do employees and their representatives have reasonable access to your occupational injury and illness records? OSHA 300-A Annual Summary At the end of each calendar year, do you complete the annual summary of occupational injuries and illnesses? Do you enter the total number of each type of case in Columns G, H, I, and J from the 300 Log? Continued 645-9

12 BLR Checklist Continued Do you enter the total number of days away from work in Column K and the total number of job transfer or restriction in Column L? YES NO Do you total the types of injuries and illnesses in Column M? Does a company executive certify that he or she has examined the OSHA 300 Log and reasonably believes that the annual summary is correct and complete? Is the annual summary posted in a conspicuous place where other employee notices are posted between February 1 and April 30? OSHA 301 Incident Report Do employees know how to report injuries and illnesses? Is an OSHA 301 Incident Report completed for each injury or illness entered on the OSHA 300 Log? Have you completely filled out the required information about the employee? Have you completed the required information about the physician or other health care professional involved in diagnosis and treatment of the injury or illness? Has the company representative who completed the incident report signed his or her name, dated the report, and provided a phone number at which he or she can be reached? If you use an insurance form instead of the OSHA 301 Incident Report, does this form contain the same information in a readable and understandable format, and is it completed using the same instructions as the OSHA Incident Report form?

13 Checklist Requirements Checklist YES NO OSHA 300 Log Have you entered a number that is unique for each case in Column A? Have you entered the employee s name in Column B? Have you specified the employee s regular job title in Column C? Have you entered the date of the injury or onset of the illness in Column D? Have you listed in Column E where the incident occurred? Have you briefly described in Column F the nature of the injury? Have you classified the case by checking only the most serious result for each case (death in Column G, days away from work in Column H, job transfer or restriction in Column I, or other recordable case in Column J)? Have you entered the number of days away from work in Column K? Have you entered the number of days of transfer or restriction in Column L? In Column M, have you checked the Injury box or have you checked a box for a particular type of injury? Do employees and their representatives have reasonable access to your occupational injury and illness records? OSHA 300-A Annual Summary At the end of each calendar year, do you complete the annual summary of occupational injuries and illnesses? Do you enter the total number of each type of case in Columns G, H, I, and J from the 300 Log? Continued

14 BLR Checklist Continued Do you enter the total number of days away from work in Column K and the total number of job transfer or restriction in Column L? YES NO Do you total the types of injuries and illnesses in Column M? Does a company executive certify that he or she has examined the OSHA 300 Log and reasonably believes that the annual summary is correct and complete? Is the annual summary posted in a conspicuous place where other employee notices are posted between February 1 and April 30? OSHA 301 Incident Report Do employees know how to report injuries and illnesses? Is an OSHA 301 Incident Report completed for each injury or illness entered on the OSHA 300 Log? Have you completely filled out the required information about the employee? Have you completed the required information about the physician or other health care professional involved in diagnosis and treatment of the injury or illness? Has the company representative who completed the incident report signed his or her name, dated the report, and provided a phone number at which he or she can be reached? If you use an insurance form instead of the OSHA 301 Incident Report, does this form contain the same information in a readable and understandable format, and is it completed using the same instructions as the OSHA Incident Report form?

15 You fatalities have to or report multiple any hospitalizations work-related to OSHA by mail within one week of the incident. If you have multiple business establishments, you have to keep a separate OSHA 300 Log for each one. The annual summary of occupational injuries and illnesses (OSHA 300-A form) must be posted for employees to see between January 1 and February 1 of each year. When an employee must take days off from work because of a work-related injury or illness, you must record the incident on the OSHA 300 Log and enter the number of days away from work. You only have to record injuries and illnesses that have been diagnosed by a physician or other licensed health care professional. Quiz Requirements Quiz Answers: Please choose the correct answers for the following: The regulation requires you to explain to employees how they should report injuries and illnesses on the job. Privacy concerns are overridden in cases of occupational injuries and illnesses by OSHA s need to know who, what, where, when, and how an injury or illness occurred. As long as you keep your OSHA 300 Log up-to-date, you don t need to fill out individual incident reports for each injury and illness. Returning an OSHA annual survey form or a BLS survey form is voluntary. An employee steps on a rusty nail and gets a tetanus shot at the walk-in clinic. This is an example of an OSHA recordable case. 1. False. You must report these incidents by telephone or in person to your nearest OSHA area office within eight hours. 2. True. 3. The summary (form 300-A) must be posted from February 1 until April 30 of the year following the year covered by the records. 4. True. 5. False. In addition to diagnosed injuries and illnesses, you must record all injuries or illnesses that result in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. 6. True. OSHA wants to encourage employee involvement in recordkeeping and reporting. Therefore, employees should also have at least limited access to your records as well. 7. False. The regulations specifically account for cases in which privacy concerns need to be addressed. 8. False. In addition to entering injuries and illnesses on the OSHA 300 Log, you must also fill out a separate report (form 301) for each incident. 9. False. You are required to complete and promptly return these surveys if you receive one. 10. False. No, this is not a recordable case. A tetanus shot is defined as first aid

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