Jessica Schroeder CESA 10 Environmental Health and Safety Program Manager March 2014

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1 Recordkeeping Jessica Schroeder CESA 10 Environmental Health and Safety Program Manager March 2014

2 Recordkeeping History 1971 Recordkeeping requirement established January 19, 2001 Final rule published January 1, 2002 Effective date January 1, 2003 New hearing loss recording criteria effective January 1, 2004 Forms revised to incorporate hearing loss column

3 Recordkeeping Goals Protect privacy Improve data Simplify forms Maximize use of computers Improve employee involvement Provides clearer regulatory requirements

4 Recordkeeping OSHA Recordkeeping regulation (29 CFR 1904) Employers are required to prepare and maintain records of serious occupational injuries and illnesses, using the OSHA 300 Log Information important for employers, workers & OSHA Used to evaluate: the safety of a workplace understand industry hazards implement worker protections to reduce and eliminate hazards

5 Forms Three federal 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 One state recordkeeping form SBD Summary of Work-Related Injuries and Illnesses Report

6 OSHA Form 300

7 OSHA Form 301

8 OSHA Form 300A OSHA Form 300A

9 SBD Summary

10 What am I required to report? All employers must report the death of any employee from a work-related incident or the in-patient hospitalization of three or more employees as a result of a work-related incident within eight (8) hours Contact the department during normal business hours: or During non-business hours: The State Division of Emergency Management can be contacted at

11 Am I required to prepare and maintain records? Employers with more than ten employees Whose establishments are not classified as a partially exempt industry Partially exempt industries include establishments in specific low hazard retail, service, finance, insurance or real estate industries. Must record work-related injuries and illnesses using approved forms

12 Preparing and maintaining records? Because you are required to keep Form 300, the Injury and Illness log You must post Form 300A, the Summary of Work-Related Injuries and Illnesses Every year from February 1 to April 30 Current and former employees, or their representatives, have the right to access injury and illness records Employers must give the requester a copy of the relevant record(s) by the end of the next business day

13 What is recordable under the Reg? All work-related fatalities All work-related injuries and illnesses that: result in days away from work restricted work transfer to another job loss of consciousness medical treatment beyond first aid

14 What is recordable under the Reg? Significant work-related injuries or illnesses diagnoses by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness

15 What is recordable under the Reg? New work-related injuries and illnesses: 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

16 What is recordable under the Reg? Injuries include but not limited to, a cut, fracture, sprain, or amputation Illnesses include both acute and chronic illnesses: skin disease (i.e. contact dermatitis), respiratory disorder (i.e. occupational asthma, pneumoconiosis), or poisoning

17 What is first-aid? Using a non-prescription medication at nonprescription strength Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment) Cleaning, flushing or soaking wounds on the surface of the skin Using wound coverings such as bandages, Band-Aids, gauze pads, or using butterfly bandages or Steri-Strips (other wound closing devices such as sutures, staples, are considered medical treatment)

18 First-aid Continued Using hot or cold therapy Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. Using temporary immobilization devices while transporting an accident victim (e.g., splints, back boards) Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister Using eye patches

19 First-aid Continued Removing foreign bodies from the eye using only irrigation or a cotton swab Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means Using finger guards Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes) Drinking fluids for relief of heat stress

20 The OSHA Recordkeeping Handbook The OSHA Recordkeeping Handbook is a compendium of existing agency approved policy, including the 2001 Recordkeeping rule (Regulatory text and relevant decision discussion from the Preamble to the rule), Frequently Asked Questions and the Letters of Interpretation.

21 Recording Criteria Decision Tree NO Did the employee experience an injury or illness? YES NO Is the injury or illness work-related? YES Is the injury or illness a new case? YES NO Update the previously recorded injury or illness entry if necessary. NO Does the injury or illness meet the general recording criteria or the application to specific cases? YES Do not record the injury or illness Record the injury or illness

22 Work Related 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 Is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment 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

23 Work Related Exceptions 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

24 Recording Needlesticks Requires employers to record all needlestick and sharps injuries involving contamination by another person s blood or other potentially infectious material

25 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 1 A STS is defined in OSHA s noise standard at 29 CFR (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.

26 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

27 Employee Involvement Requires employers to establish a procedure for employees to report injuries and illnesses Requires employers to tell their employees how to report Must set up a way for employees to report promptly; and Must tell each employee how to report to you Employers are prohibited from discriminating against employees who do report Employee representatives will now have access to those parts of the form relevant to workplace safety and health Must provide limited access to injury and illness records to employees, former employees and their representatives

28 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

29 Process Did the employee experience an injury or illness? YES Is the injury or illness work-related? YES Is the injury or illness a new case? YES Does the injury or illness meet the general criteria or the application to specific cases? YES RECORD THE INJURY OR ILLNESS

30 Timeline Employers must enter each recordable case on the forms within 7 calendar days of receiving information that a recordable case occurred Retain forms for 5 years following the year that they cover

31 Covered Employees Employees on payroll Employees not on payroll who are supervised on a day-to-day basis Exclude self-employed and partners Temporary help agencies should not record the cases experienced by temp workers who are supervised by the using firm

32 Annual Summary Review summary form for completeness and accuracy, correct deficiencies Certify summary Post summary A company executive must certify the summary Must post for 3-month period February 1 to April 30 Year following the year covered by the summary

33 CONTACT INFORMATION Jessica Schroeder CESA 10 Environmental Health and Safety Program Manager

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