OSHA Recordkeeping and Reporting Taking the pain out of Injury and Illness Reporting
Topics we will cover OSHA Regulation 29 CFR 1904 overview Work-relatedness Recordable or not Counting lost/restricted time Completing an OSHA 300 Log Injury/illness reporting requirements Calculating your incident and severity rates
29 CFR 1904 Overview Subpart A Purpose Subpart B Scope Subpart C Recordkeeping Forms and Recording Criteria Subpart D Other Requirements Subpart E Reporting to the Government Subpart F Transition Subpart G Definitions
Subpart A - Purpose Requires employers to record and report work-related fatalities, injuries and illnesses Does not mean that the employer or employee was at fault, that an OSHA rule has been violated, or that the employee is eligible for workers' compensation or other benefits
Subpart B - Scope Less than 10 employees at all times throughout the year Unless directed by OSHA or BLS All employers must report certain workplace incidents More than 10 employees Unless classified as partially exempt New list of exempt Industries https://www.osha.gov/recordkeeping/ppt1/rk1exempttable.html List of newly covered industries https://www.osha.gov/recordkeeping2014/reporting_industries.html
Subpart C 1904.4 Recording Criteria No No No Did the employee experience an injury or illness? Yes Work Related? Yes New Case? Yes General Recording Criteria No Yes Update Previous Case Do Not Record Record
Work Related An event or exposure in the work environment caused or contributed to the injury/illness or significantly aggravated a pre-existing condition. Geographical Presumption The work environment is the establishment and other locations where one or more employees are working or are present as a condition of their employment. Not only physical location, but also includes the equipment or materials used by employee.
Work Related 1904.5(b)(2) Except: Member of the general public Signs/symptoms from non-work-related event Results solely from voluntary participation in a wellness program Eating/drinking or preparing food for personal consumption Personal tasks outside of normal work hours Personal grooming/self inflicted Caused by a motor vehicle accident Common cold or flu Mental illness
Significantly Aggravated Pre-existing resulted solely from a nonwork-related event/exposure outside of the work environment. Death Loss of consciousness One or more days away from work, restricted work, or days of job transfer Medical cases
Other Locations Travel Engaged in work activities in the interest of the employer Except: Established a home away from home Taken detour for personal reasons Working from home
Subpart C 1904.4 Recording Criteria No No No Did the employee experience an injury or illness? Yes Work Related? Yes New Case? Yes General Recording Criteria No Yes Update Previous Case Do Not Record Record
New Case The employee has not previously experienced a recorded injury/illness of the same type that affects the same body part Had previously experience a recorded injury/illness but had recovered completely
Subpart C 1904.4 Recording Criteria No No No Did the employee experience an injury or illness? Yes Work Related? Yes New Case? Yes General Recording Criteria No Yes Update Previous Case Do Not Record Record
General Recording Criteria Death Days away from work Restricted work or transfer to another job Medical treatment beyond first aid Loss of consciousness Significant Injury or illness
Days away from work One or more days away from work Do not count the day the injury/illness occurred Calendar days Cap at 180 days Days away are recorded on the 300 Log for the year when the injury/illness occurred. You can estimate days until total is known
Restricted Work or Transfer Restricted - Employee is kept from performing one or more routine functions or not work a full workday that he or she would have been scheduled to work. Routine functions regularly performs once a week Transfer assigned to a job other than his or her regular job for part of a day. Counting days the same as days away
Medical Treatment Management and care of a patient to combat disease or disorder Does not include: Visit to a physician solely for observation and counseling Diagnostic testing including prescriptions for diagnostic purposes
Medical Treatment Prescription strength Ibuprofen > 467mg Benadryl > 50mg Aleve > 220mg Sutures, staples and surgical glue to close a wound Rigid splints Physical therapy and chiropractic treatment
Medical Treatment Beyond First Aid Non-prescription medication at nonprescription strength Immunizations (tetanus) Cleaning, flushing or soaking a wound on skin surface Wound coverings Hot and cold therapy Non-rigid support Temporary immobilization during transport
First Aid Continued Drilling of a fingernail, toenail or blister to relieve pressure Using an eye patch Removing foreign bodies from the eye using only irrigation or a cotton swap Removing splinters Using finger guards Using massages Drinking fluids for heat stress
Significant Injury/Illness Loss of consciousness Cancer Chronic irreversible disease Fracture or cracked bone Punctured ear drum Kinesiology tape
Summary so far Death Days away from work Restricted work or transfer to another job Medical treatment beyond first aid Loss of consciousness Significant Injury or illness
OSHA Forms 300 Log 301 Form 7 days from receiving information of a recordable case 300-A Summary Certified by company executive Posted Feb. 1 st April 30 th Privacy Cases https://www.osha.gov/recordkeeping/tutorial/player.html
Reporting Requirements Fatalities 8 hours Inpatient hospitalizations of one or more 24 hours Amputations 24 hours Loss of an eye 24 hours
Reporting Requirements Do not have to report an event if Resulted from a motor vehicle accident on a public street or highway unless in a construction zone. Occurred on public transportation system Occurred > 30 days after the incident for fatalities Occurred > 24 hours after incident for inpatient hospitalization, amputation or loss of eye
Reporting Requirements Call your local OSHA office Indianapolis Area Office 46 East Ohio Street, Room 453 Indianapolis, Indiana 46204 (317) 226-7290 (317) 226-7292 FAX Call OSHA 24 hour hotline at 1-800-321- OSHA (6742) Online at www.osha.gov (coming soon)
Reporting Requirements Establishment name Location of the work-related incident Time of the work-related incident Type of reportable event (i.e., fatality) Number of employees who suffered the event Names of the employees who suffered the event Contact person and his or her phone number Brief description of the work-related incident
Calculating Incident Rates TRIR Total Recordable Incident Rate DART Rate Days Away and Restricted Time Incident Rate = number of incidents 200,000 total hours worked BLS Incident Rate Calculator http://data.bls.gov/iirc/?data_tool=iirc Severity Rate # of LW days/lwd Cases
Questions? Dominique Phillips Phone: 317.916.3137 E-mail: dphililps@augustmack.com For other August Mack Webinars, please visit: www.augustmack.com/webinarcalendar.asp