OSHA Injury and Illness Co-Sponsored by Presented by Mark Flannery Director of Environmental Affairs 1 (508) 804-4107 mflannery04@pine.org 2 Am I Covered? Covered Employees 3 Manufacturing, Agriculture, Construction, Wholesale Trade Among Others Are Covered. Printers Are Not Exempt. Have 10 Or More Employees. Based On Total Number of Employees In Company Peak from Previous Calendar Year. Include Temporary Employees Who Are Directly Supervised On A Day-To-Day Basis. Need To Complete Forms. Have 10 Or Fewer Employees. Must Report Fatalities & Significant Events. 4 Employees On Payroll. Temporary Or Permanent Employees Not On Payroll, But Supervised Day-To-Day Basis. Exclude Self-Employed and Partners. Do Not Need To Record Injuries or Illnesses. Forms Form 301: Injury and Illness Incident Report Form 300: Log of Work-related Injuries and Illnesses Form 300A: Summary of Work-related Injuries and Illnesses Allows All Forms To Be Kept On Computer Equipment Or At Alternate Location Decision Tree NO Did the employee experience an injury or illness? NO Is the injury or illness work-related? NO Update the previously Is the injury recorded injury or illness or illness a new case? entry if necessary. NO Does the injury or illness meet the general recording criteria or the application to specific cases? Do not record the injury or illness Record the injury or illness 5 6 1
General Requires Recording Any Work-Related 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 Physician or Other Licensed Health Care Professional (PLHCP) Medical Treatment Includes Managing and Caring For A Patient for the Purpose of Combating Disease or Disorder. Does Not Include Visits Solely For Observation/Counseling Does Not Include Diagnostic Procedures Including Administering Prescription Medication For The Procedure. Note: Exposures in and of themselves are not recordable. 7 8 First Aid Provide First Aid Definition (Not Recordable) Using Non-Prescription Drugs In Non-Pres Strength Tetanus Immunization All Others Treatment Cleaning, Flushing, or Soaking Wounds Using Wound Coverings or Butterfly Closures Hot or Cold Therapy Using Non-Rigid Means of Support Elastic Bandages Temporary Use of Splints\Other Immobilizers Drilling Fingernails\Toenails or Draining Blisters First Aid Provide First Aid Definition (Not Recordable) Splinter Removal By Simple Means Removing Foreign Bodies From Eye By Simple Means Using Eye Patches Using Massages Not PT or Chiropractic Treatment Using Finger Guards Drinking Fluids For Heat Stress Relief 9 10 Recording Needlesticks Must Record All Needlestick and Sharps Injuries Involving Contamination By Another Person s Blood or Other Potentially Infectious Material Hearing Loss OSHA Changed Effective 2003 Defines Standard Threshold Shift (STS) as: A change in hearing threshold, relative to the most recent audiogram for that employee, of an average of 10 decibels Requires Recording Hearing Loss Cases when STS occurs and employee s average hearing level is 25 decibels above audiometric zero. 11 12 2
Work-Relatedness Cases Are Work-Related If: An Event or Exposure In The Work Environment Either Caused or Contributed To The Condition. An Event or Exposure In the Work Environment Significantly Aggravated A Pre-Existing Inj/Ill. Death Loss Of Consciousness Days Away, Days Restricted, or Job Transfer. Medical Treatment. Separate Criteria Work-Related TB Transmission. Work-Related Exceptions Limits Recording of Cases Involving Injury Or Illness Symptoms Surfacing At Work, But Are Not Work Related (e.g., epileptic seizure, diabetic reaction, etc.) Personal Tasks Outside Assigned Working Hrs. Present As A Member Of The General Public. Intentionally Self-Inflicted. Eating, Drinking, or Preparing Food Or Drink For Personal Consumption. Blood Donation. 13 14 Work-Related Exceptions Limits Recording of Cases Involving Common Colds and Flu Voluntary Participation In Wellness, Fitness, or Recreational Programs Personal Grooming Self-Medication For Non-Work Related Condition Motor Vehicle In Parking Lot During Commute. Mental Illness. Travel or Work At Home Injuries/Illnesses Occurring During Travel or Work At Home Recordable If Activity Is Directly Related Or Benefiting Employer. Also Applies To Home Away From Home. Detours For Personal Reasons Not WR. General Home Activities Inj/Ill Not WR. 15 16 Musculoskeletal Disorders Applies Same To Musculoskeletal Disorders (MSDs) As All Other Injuries and Illnesses. Employer Has Flexibility To Determine Whether An Event Or Exposure In The Workplace Caused Or Contributed To the MSD OSHA Currently Proposing a Separate Column on the OSHA 300 Log This is 1 st step toward implementing a new Ergonomics rule. Light Duty Or Restricted Work Clarification Must Record Cases When Injured/Ill Employee Is Restricted From Normal Duties. Normal Duty Definition: Duties The Employee Performs At Least Once Per Week. Employee Is Kept From Working A Full Day. A PLHCP Recommends Either Of The Above. 17 18 3
Day Counts Counting Days For Lost/Restricted Work Count Calendar Days (not scheduled work days) 180 Day Cap Do Not Include Day Of Injury/Illness Stop Counting Days If Employee Leaves Company For Non- Injury/Illness Reasons Employee Reporting Requirements Must Establish Procedure For Employees To Report Injuries and Illnesses. Employers Must Tell Employees How To Report. Employers Prohibited From Discriminating Against Employees Who Report. With Change of Ownership, Seller Must Turn Over OSHA Records To Buyer. 19 20 Privacy Protection Prohibits Entering Employee s Name On Form 300 For Certain Types of Injuries/Illnesses Sexual Assaults HIV Infections Mental Illness Keep A Separate Identity List. Privacy Protection Can Omit Injury Description For Sensitive Injuries Where Employee s Identity Would Be Known. Gives Employee, Former Employee, or Representative Ability To Get Copy of Form 301 For Their Own Injury or Illness. Must Remove Employees Names Before Providing Data To Persons Not Authorized. Employee Reps Only Allowed Portion of Form 301 Which Contains No Personal Information. 21 22 Annual Summary Annual Summary Posting Extended. February 1 to April 30 Company Official To Certify Annual Summary. Information Is True Accurate and Complete. 23 24 4
Calculating Total Recordable Case Rate Total Number of Injury & Illnesses Number of Hours Worked by All Employees X 200,000 = Total Recordable Case Rate 200,000 represents 100 employees working 40 hours/week, 50 weeks/year 25 26 Calculating DART Incidence Rate Retention and Updating Forms Number of Entries Column H + I Number of Hours Worked by All Employees X 200,000 = DART Retain All Forms For 5 Years Following The Year That They Cover. Update Form 300 During 5 Year Period. Do Not Need To Update Form 300A or 301. 200,000 represents 100 employees working 40 hours/week, 50 weeks/year 27 28 29 Reporting to OSHA Fatalities & Catastrophes Reporting Excludes Some Motor Carrier & Motor Vehicle Incidents. Public Street, Commercial Plane, Train, Bus, Subway Must Report Other Fatalities Including Heart Attack Within 8 Hours. Must Report Any Incident Resulting In Hospitalization of 3 Or More Employees. Within 8 Hours. 800-321- OSHA (6742) 30 For More Information Go to OSHA s Website www.osha.gov If interested in how to prepare for an OSHA inspection: PINE members, please call me for site visit or telephone correspondence Participate in PIA s webinar How to Prepare for the New Aggressive OSHA Inspections Free for all PIA members March 4, 2:00 PM Email Joe Marin at PIA to Register, jmarin@printing.org 5