Workplace Injuries: Controls & Recordkeeping

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1 Workplace Injuries: Controls & Recordkeeping Health and Safety Management Professional Certificate in Human Resources Injuries, Controls & Recordkeeping Defining a workplace Injury Workplace Illnesses What does OSHA have to say? Recordkeeping, Reporting Elements of Injury Controls 2 Workplace Injuries Defined: Occurs at the workplace Recordable vs Non-Recordable Requirements & Expectations Why track them Reveal hazards Determine program weaknesses Judge effectiveness of controls Analysis and investigation Identify Causes OSHA Requirements 3

2 4 Recordable 300 Log 300 A OSHA 301 Incident Report First Aid vs. Medical Treatment, Lost Time Fatalities Hospitalization Treatment above first aid 10 or more employees Illness vs. Injury Recordable Lost time (more than the day of the injury) Restricted duty (Modified duty) Transfer Medical Treatment Prescription meds Hospitalization >24 hours (more than observation Loss of Consciousness Significant injury, amputation, fatality 5

3 (b)(2) - Work-Relatedness Exceptions (continued) The injury or illness was caused by: a motor vehicle accident in parking lot or access road during commute a common cold or flu Symptoms surface at work that are solely due to non-workrelated event or exposure The employee was present in the work environment as a member of the general public The employee has a mental illness (unless the employee comes forward with an opinion from an Health Care Provider with appropriate training and experience that the employee has a mental illness that is work related) Recordable Temp Workers supervised by your company All employees: Seasonal, parttime, exempt, nonexempt Don t Record Self-employed individuals working at your facility Temp workers not supervised by your company Contractors supervised Customers Employees on site 8 not work-related Reporting Beyond Recording an actual call to CalOSHA (619) Within 8 hours Loss of Consciousness Hospitalization >24 hours (again, more than observation) Multiple employees (3 +) 9

4 10 Reporting and Recordkeeping Keep OSHA Form 301 Incident Reports for 5 years. OSHA 300 A Summary Post in a significant place Does not reveal personal information Posted February 1 through April 30 Multiple sites Keep on file for 5 years Why might an injury/illness summary be of interest to employees? More record Keeping Record if 10 or more employees (with some exceptions) Fatality or 3 or more employees hospitalized Separate log for each facility* Hours worked does not include PTO, jury duty, etc. Temp agency That employer keeps a 300 Log Highest Company Executive signs the form 11 When to record? Occurs within the Work Environment Traveling on company business At a job site working on company business Using tools and equipment related to work Significantly aggravates a pre-existing injury or illness One or more days away from work or modified/restricted duty 12

5 (b)(4) - Significant Aggravation A pre-existing injury or illness is significantly aggravated when an event or exposure in the work environment results in any of the following (which would not have occurred but for the occupational event or exposure): Death Loss of consciousness One or more days away from work, or of restricted work, or a job transfer Medical treatment or a change in medical treatment Consequences for non-reporting Up to $7,000 fine for Regulatory Citation. Commensurate with the seriousness of the violation Look at Request for Documents form 14 Best practices Have a safety policy Require injuries or illnesses to be reported regardless of severity Periodically train all employees on the policy and related procedures Have a centralized reporting process (One person in charge of the 300 Log Document seemingly minor injuries Have first aid supplies and trained CPR/First Aid/AED personnel 15

6 More best practices First Responders many agencies automatically notify Cal OSHA when responding to a workplace incident Call might need to be made Explanation of Report-ability Respect Privacy: Consider incident description on 300 and 300 A logs Maintain a privacy file to refer to Place a label such as Privacy Concerns Check your required DIR and DIOSH postings Dates, Phone numbers, Occupational Medicine 16 What about Lunchroom injury Employee is hurt off site at lunch Injury during a team building event On the way to work 17 Recordable? Non Recordable? Employee cuts finger with box cutter, doctor cleans the wound and applies a Band-Aid New employee cuts hand in break room on can opener, requires 8 stitches That employee with the Band-Aid now develops an infection, goes back to the Dr. and is prescribed antibiotics 18

7 19 More Recordable or Non- Recordable cases Your company s mail courier company vehicle is rear-ended by another driver, she goes to the occupational medicine facility and is off work for 3 days. Is this case covered by your company s Work Comp insurance? Record Keeping and Reporting Summary Recordkeeping is a good idea: We need to know where injuries are occurring OSHA requires it. There are important legal differences between recordable and non-recordable injuries Posting of OSHA 300A 20 Using Recording and Reporting Why would OSHA want to measure rates? What sort of trends would they look for? What can a company expect if it has a higher rate than

8 OSHA Frequency and Severity Rates OSHA RECORDABLE INCIDENT RATE - a mathematical calculation that describes the number per 100 full-time employees who have been involved in a recordable injury or illness. LOST TIME CASE RATE a mathematical calculation that describes the number of lost time cases per 100 full-time employees in any given time frame. More LOST WORKDAY RATE a mathematical calculation that describes the number of lost workdays per 100 full-time employees in any given time frame. SEVERITY RATE a mathematical calculation that describes the number of lost days experienced as compared to the number of incidents experienced. DART RATE - a mathematical calculation that describes the number of recordable incidents per 100 full time employees that resulted in lost or restricted days or job transfer due to work related injuries or illnesses. OSHA Incident Rate Number of OSHA Recordable Cases X 200,000 IR = Number of Employee labor hours worked

9 OSHA Severity Rate Total number lost workdays SR = Total number of recordable incidents Workplace Controls Minimizing exposure to hazards Administrative Non-physical changes Process Signage Engineering Tools Materials PPE Facility Environment 26 Hierarchy of Controls (p.59 Hopwood, Thompson) Administrative Controls PPE Work Practices Engineering Controls

10 Administrative Controls Preventative Practice (Evacuation Drills, Spill Response) Audits, Inspections Shift Rotations Policies PPE Procedures Certifications Sanctions (Discipline) Senior Leader Support 28 Engineering Controls physical changes to reduce exposure Machine guarding, safety features Materials toxicity, corrosiveness, handling, shipping, stability, compatibility Tools insulating, ergonomics, weight, Transfer of exposure, risk Process Assembly line, Lockout/Tagout (LOTO) Personal Protective Equipment (PPE) 29 Illnesses What is the most common work related illness today? Cumulative Trauma Disorders Repetitive Motion Disorders Chronic Occurs over time Respiratory disorders, vision & hearing impairment All work-related illnesses are recordable 30

11 Putting it all together: Injuries and controls 1. Identify hazards 1. Trend analysis: 2. Where are losses occurring? 3. Common factors 2. Engineering Controls 3. Administrative Controls 31 Sprains and Strains Analysis Practices Wellness Program Ergonomics program Scheduling Breaks Smaller packaging Roller tray PPE Fork lift Pallet jack 32 Slips, Trips & Falls Analysis Practices Housekeeping schedules, procedures Floor surface Lighting Hand rails Signage Mirrors Footwear requirements 33

12 Falls (from Height) Analysis Practices Inspections Observation Labeling Signage PPE Harnesses Hard hat Gloves Lanyards Aerial Lifts Re-engineer 34 Struck by object Analysis Practices Inspections Enforcement Safety glasses Hard hats Inspections Debris Broken equipment Footwear Lockout/Tagout 35 Repetitive Motion Disorders RMDs Cumulative Trauma Disorders-CTDs Analysis Practices Wellness Program Ergonomics program Scheduling Breaks Alternating tasks Equipment Desk Chair Keyboard Lighting Adjustments Tool grips Automation 36

13 Automobile Injuries Licensing & DMV Records New Hire Refresher Behind-the-Wheel Observation Reinforce Safe Practices Vehicle selection Service Checks Safety Checks Monitoring Route selection Timing Driving Aids Backing Alarms Oversize mirrors 37 Summary OSHA Reporting & Record Keeping When to Record When to Report Common Workplace Injuries & Illnesses Controls Administrative Work Practices PPE Engineering Controls 38

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