OSHA Recordkeeping Policy #: OGP 600

Transcription

1 OSHA Recordkeeping Policy #: OGP 600 APPROVED BY: Anthony Dallas, MD, CMO SUPERCEDES POLICY: 03/2006 ADOPTED: 03/2006 REVISED: 09/09/2015 REVIEWED: OBJECTIVE: To recognize, report, and record work-related injuries and illnesses set forth by the Occupational Safety and Health Administration (OSHA) standard 29CFR1904. SCOPE: All CareHere Health Centers PURPOSE: OSHA s record keeping requirements (1971) are designed to help employers recognize workplace hazards and correct hazardous conditions by keeping track of work related injuries, illnesses and their causes. POLICY: All CareHere Health Center sites will be required to report work related injuries/illnesses to CareHere Risk Management according to OSHA 29CFR Part This includes recording every work related injury or illness that involves loss of consciousness, restricted work activity or job transfer, days away from work or medical treatment. In addition CareHere incident reporting process must be initiated and completed as per policy requirements for all employee injuries (ADM 106). I. Basic Requirement: CareHere is required to maintain records of fatalities, injuries, and illnesses and must record each fatality, injury, and illness that: 1. Is work related; and 2. Is a new case; and 3. Meets one or more of the general recording criteria II. Determination of work relatedness: An injury or illness is to be considered work related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work relatedness is presumed for injuries or illnesses resulting from events or exposures occurring in the work environment, unless an exception in (b) (2) specifically applies (OSHA- 600b: OSHA Work Related Exceptions). III. Determination whether a particular injury or illness is recordable is explained in the decision tree (OGP- 600a: OSHA Determination of Recordability) IV. Determination of new cases: an injury or illness is to be considered a new case if: a. The employee has not previously experienced a recorded injury or illness of the same type that effects the same part of the body; or b. The employee previously experienced a recorded injury or illness of the same type that effected the same part of the body but had recovered completely (all signs and symptoms had disappeared) from the previous injury or illness and event or exposure in the work environment caused the signs or symptoms to reappear. V. General recording criteria: an injury or illness is considered to meet the general recording criteria and therefore be recordable on the OSHA 300 log if it results in any of the following: Death Days away from work Restricted work or transfer to another job

2 Medical treatment beyond first aid Loss of consciousness A significant injury or illness diagnosed by a physician or other licensed health care professional A. Recording and Reporting Occupational Injuries and Illnesses ( ): The Director of Clinical Services (DCS) or Clinic Manager should report to OSHA any of the following during the specified time periods: i. Within eight (8) hours of discovery 1. The death of any employee as a result of a work-related accident ii. Within twenty-four (24) hours of discovery of any of the following occurring due to a work-related incident: 1. In-patient hospitalization of one or more employees 2. Amputation 3. Loss of an eye Additional reporting guidelines i. If a fatality occurs within 30 days of the work-related incident, or if an in-patient hospitalization, amputation, or loss of an eye occurs within 24 hours of the workrelated incident, then you must report the event to OSHA. ii. If the fatality occurs more than 30 days after the work-related event, or if the inpatient hospitalization, amputation, or loss of an eye occurs after more than 24 hours after the work-related event, then you do not have to report the event to OSHA. Incidents can be reported to the OSHA Area Office that is nearest to the site of the incident; by telephone to the OSHA toll-free number at OSHA ( ) or by electronic submission on B. Recording work-related injury or illness that results in days away from work: When an injury or illness involves one or more days away from work, the case is recorded on the OSHA 300 log with a check mark in the space for cases involving days away and an entry of the number of calendar days away from work in the number of days column. If the employee is out of work for an extended period of time, employers enter an estimate of the days that the employee will be away, and update the day count when the actual number of days is known. Begin counting days away on the day after the injury or illness began. It is not required to keep track of the number of calendar days away from work if the injury or illness resulted in more than 180 calendar days away from work. In such a case, entering 180 days in the total days away column will be considered adequate. If the injury or illness involved both days away from work and days of restricted work activity enter the total number of days for each. You may stop counting days of restricted work activity or days away from work once the total of either or the combination of both reaches 180 days. If a case occurs in one year but results in days away during the next calendar year, enter the number of calendar days away for the injury or illness on the OSHA 300 log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when the annual summary is prepared, estimate the total number of calendar days you expect the employee to be away from work. Use this number to calculate the total for the annual summary then update the initial log entry later when the day count is known or reaches the 180-day cap. C. Recording work related injury or illness that results in restricted work or job transfer: Restricted work occurs when as a result of a work related injury or illness;

3 VI. The employee is not able to perform one or more of the routine functions of his job, or from working the full work day that he or she would otherwise have been scheduled to work, or: physician or other licensed health care professional recommends that the employee not perform one or more of the routine functions of his or her job, or not work the full workday that he or she would otherwise have been scheduled to work Routine functions are those work activities the employee performs at least once a week. Do not record restricted work or transfer if it is written only for the day on which the injury occurred or illness began. When an injury or illness involves restricted work or transfer, record the injury or illness on the OSHA 300 log by placing a check mark in the space for job transfer or restriction and an entry of the number of restricted or transferred days in the restricted workdays column. If an injured or ill employee is assigned to a job other than his or her regular job for part of the day, the case involves transfer to another job. This does not include the day on which the injury or illness occurred. Employers are not required to keep tracking the number of calendar days restricted and/or job transfer from work if the injury or illness resulted in more than 180 calendar days. In such a case, entering 180 days in the job transfer or restriction column will be considered adequate. If the injury or illness involved both days away from work and days of restricted work activity enter the total number of days for each. You may stop counting days of restricted work activity or days away from work once the total of either or the combination of both reaches 180 days. D. Medical treatment If a work related injury or illness results in medical treatment beyond first aid it must be recorded on the OSHA 300 log. First aid is defined in the (OGP-600c: What is First Aid?). Please note that this is a complete list of all treatments considered first aid for OSHA recording keeping. If the injury or illness did not involve death, one or more days away from work, one or more days restricted work, or one or more days transfer, employers enter a check mark in the box for cases where the employee received medical treatment but remained at work and was not transferred or restricted. E. Loss of consciousness is recordable if the worker becomes unconscious regardless of the length of time the employee remains unconscious. F. A significant injury or illness diagnosed by a physician or other licensed health care professional: work related cases involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum must always be recorded under the general criteria at the time of diagnosis by a physician or other healthcare professional. Recording criteria for needle stick and sharps injuries: Employers must record all work related needle stick injuries and cuts from sharp objects that are contaminated with another person s blood or other potentially infectious material (OPIM). Other Potentially Infectious Material (OPIM) refers to human bodily fluids, tissues and organs, and other materials infected with HIV or hepatitis B virus. All needlestick and sharps injuries must be entered on the OSHA 300 log as an injury, and on the CareHere s Sharps Injury Log (OGP-600f: Needlestick, Sharps Injury, Privacy Log). To protect the employee s privacy employers may not enter the employee s name on the OSHA 300 log. Instead, enter privacy concern case in the space normally used for the employee s name

4 Employers must keep a separate confidential list of the case numbers and the employee names for your privacy concerns cases so you can update the cases and provide the information to the government if asked to do so. VII. Other cases determined to meet the privacy concern case category include the following: Injury or illness to an intimate body part or reproductive system Injury or illness resulting from a sexual assault Mental illnesses HIV infection, hepatitis, or tuberculosis Needlestick injuries and cuts from sharp objects that are contaminated with another person s blood or other potentially infectious material (OPIM) Other illnesses, if the employee independently and voluntarily requests that his or her name not be entered on the log. VIII. Other cases determined to meet recordable include: If an employee s hearing test (audiogram) reveals that the employee has experienced a workrelated Standard Threshold Shift (STS) in one or both ears, and the employee s total hearing level is 25 decibels (db) or more above the audiometric zero (averaged at 2000, 3000, and 4000 Hz) in the same ear(s) as the STS, the case will be recorded on the OSHA 300 log by checking the hearing loss column. An employee that has been occupationally exposed to a known case of active tuberculosis and this employee subsequently develops tuberculosis infection as evidenced by a positive skin test or diagnosed by a physician or other health care professional. Report the case to Risk Management so they can record the case on the OSHA 300 log. This will be included in the respiratory condition column. IX. Required Forms: a. OSHA 301 Form/Incident Employee Information Form Both forms must be filled out and submitted to Risk Management (risk@carehere.com) when a recordable injury or illness has occurred. Health Centers must use the CareHere Incident Employee Information form. The CareHere version is an equivalent form that meets the OSHA requirements of the 301 forms (OGP-601: OSHA 301 Form). Instructions on how to complete this form can be found in OGP-601. The employee/supervisor must fill out this form within 48 hours of receiving information that a recordable work related injury has occurred and submit to Risk Management (risk@carehere.com). b. OSHA 300 Log: Instructions for completing the OSHA 300 log are available online at: It must be determined within 7 calendar days after information about the case is received if the case is recordable under the OSHA record keeping requirements. c. Annual Summary OSHA 300 A: At the end each calendar year, the following must occur: The OSHA 300 Log must be reviewed to verify the entries are complete and accurate. Any deficiencies must be corrected. An Annual Summary 300A of all injuries/illnesses recorded on the OSHA 300 log must be created for each location. The 300A will be completed by Risk Management and provided to the health center. The certified OSHA 300A must be posted no later than February 1 of the year following the year covered by the records and needs to remain in place at least until April 30. X. Retention and Updating Records: Retain the OSHA 300 Log, the privacy list, the annual summary and the OSHA 301 Incident report forms for five (5) years following the end of the calendar year that these records cover.

5 During the storage period, update your stored OSHA 300 log to include newly discovered recordable injuries or illnesses and to show changes that have occurred in the classification of previously recorded injuries and illnesses. If the description or outcome of the case changes you must remove or line out the original entry and enter the new information.