MIOSHA Recordkeeping Summary Report Injury and Illness Reporting & Recordkeeping Standards and Process



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January 29, 2005 MIOSHA Recordkeeping Summary Report Injury and Illness Reporting & Recordkeeping Standards and Process Public posting of the MIOSHA Summary of Work-Related Injuries and Illnesses (Form 300A) is required from February 1 through April 30, 2005. The report is electronically available on the Work~Connections website (http://www.umich.edu/~connect/miosha.htm) and has also been widely broadcast electronically and through mailed communications. The report summarizes the University s volume and types of reported illnesses and injuries by organizational areas, referred to as establishments in MIOSHA terms. The establishments include Dearborn Campus, Flint Campus, Ann Arbor Campus and Hospitals and Health Centers (UMHHC) 98% of the injuries reported and recorded were sustained by the latter two areas of the University. Both Ann Arbor and UMHHC establishments have shown steady improvement not only in total claims reported but also declines in total days away from work (shown later). Ann Arbor accounts for approximately 40% of all claims recorded and the Hospitals and Health Centers represent 58.75%. Total Cases by Reporting Area 2002 2003 2004 3-year average % of Total Cases Dearborn 19 8 14.74% Flint 22 21 6.88% Ann Arbor Campus 805 762 630 39.63% Hospitals and Health Centers 1159 1093 1005 58.75% Total Cases Reported 2005 1884 1655 100.00% Hospital Area 58% Flint 1% Dearborn 1% Ann Arbor Campus 40% Percent of Total Cases: CY 2002-2004 CY 2002-2004: Ann Arbor and UMHHC Cases 900 800 805 762 700 1159 600 630 500 1093 400 300 1005 200 100 0 2002 2003 2004 1200 1150 1100 1050 1000 950 900 Ann Arbor Campus Hospital/Health Centers

In Calendar Year (CY) 2004, the University reported 12.15 percent fewer cases than in the previous year. The graph below reflects total cases reported over the last 9 years. The spike in 2002 reflects a change in the recordkeeping standard (related to needlestick exposures) and does not signal an increase in claim frequency. If needlestick cases were excluded from counts, total cases would have continued on a gradual decline (shown in red below). MIOSHA Recordkeeping: Total Cases by Calendar Year 2,500 2,000 1,500 1,000 500 1366 1294 1107 0 1996 1997 1998 1999 2000 2001 2002 2003 2004 Total Cases 1,467 925 919 1,319 1,240 1,158 2,005 1,884 1,655 Injuries By Cause The University recorded 639 needlestick claims in CY 2002, 590 in CY 2003 and 548 in CY 2004. There has been considerable effort to reduce sharps injuries by UMHHC ranging from promoting safety devices to education and training. The Operating Rooms continues to sustain the highest frequency of claims and are currently engaged in education and reduction efforts by the UMHHC Infection Control Committee, Safety Management Services, and Employee Health Services. While the highest incidence of recordable claims are due to needlestickexposure claims (in terms of total claims), the next most frequent claims are related to lifting and carrying and slip and fall incidents. Cut/Puncture Repetitive 3% Movement 5% Pushing/Pulling 8% Other 4% Exposure 44% Struck Against 8% Slip/Fall 12% Lifting/Carrying 16%

Days Away and Restricted Days Away From Work The most recent three years, CY 2002-2004 continue to reflect improvement: Overall cases decreased 12.15% from 2003 (6% decrease from 2002 to 2003) Total cases with days away remain steady (5 year average of 191: 186 reported this year; CY 2003 was the highest of the 5 years); Total days away from work decreased 3.46% this year, following a 7.9% increase from 2002 to 2003 Total restricted cases decreased 3.7% over last year and 2% the year before. Total restricted days decreased 30% this year and 10% the year before. MIOSHA Recordable Claims 2002 2003 2004 Total Cases 2,005 1,884 1,655 Cases with Days Away From Work 189 214 186 Number of Days Away From Work 5,440 5,871 5,668 Total Cases with Restricted Activity 523 512 493 Number of Days with Restricted Activity 19,521 17,538 12,274 Establishment-Specific Data Sets: Ann Arbor Campus: Cases with Days Lost 54 68 54 Total Days Lost 1394 2202 2219 Cases with Restricted Days 270 279 244 Total Restricted Days 7719 7689 5433 Total Cases 805 762 630 Ann Arbor Campus (2-Year History: Total Cases by Recharge Area) Year: 2003 2004 University Press 0 0 University Musical Soc 0 1 Alumni Association 1 1 Athletics 6 5 General Fund 186 138 Plant 169 150 Plant Extension 3 2 Parking & Transportation 3 1 University Unions 16 17 ITD 6 6 ISR 7 7 Housing 112 90 Medical School 249 206 Health Service 4 6 Total Cases: Ann Arbor Campus 762 630

Dearborn Campus Cases with Days Lost 6 3 7 Total Days Lost 289 97 290 Cases with Restricted Days 7 3 3 Total Restricted Days 460 292 108 Total Cases 19 8 14 Flint Campus Cases with Days Lost 4 5 0 Total Days Lost 92 138 0 Cases with Restricted Days 8 4 2 Total Restricted Days 246 393 25 Total Cases 22 21 6 Hospitals and Health Centers Cases with Days Lost 125 138 125 Total Days Lost 3,665 3,434 3,159 Cases with Restricted Days 238 226 244 Total Restricted Days 11,096 8,984 6,708 Total Cases 1,159 1,093 1,005 The improvement is related to the overall coordination of injuries and illnesses throughout the University. Several units have a solid history of appropriate attention to injury data, particularly among UMHHC, Plant and Housing Departments. Both UMHHC and Plant track Lost Work Day Case Rate data monthly. And, while MIOSHA does not reflect nonoccupational claim data, the University s awareness of managing time away from work whether work-related or non-work-related has no doubt improved its overall management of absence and reinforced its commitment to early-return-to-work programs. Claim management itself is contributing to the improvement. Claim and medical treatment coordination through departments, Safety (OSEH and SMS), MWorks/EHS, and Work~Connections certainly in partnership with units actively bringing employees back to work when medically appropriate to do so, has enabled the University to create a culture of timely reporting and an orientation that supports early return-to-work. Reductions in days away from work and restricted days have been achieved through the claim staff s application of disability duration guidelines, medical case management interventions, independent medical evaluations, and actively communicating return-to-work expectations to employeesupervisor-treating doctor.

Injury Reporting and Recordkeeping Process: Initial Report - Treatment Coding and Recordkeeping Coordination An employee reports an injury/illness to supervisor; receives medical treatment; Claim must be reported to W~C within 24 hours. Claim is coded at W~C for: department, job classification, OSHA recordability, location, type of injury, body part injured and total lost and/or restricted days OSHA logs are regularly reviewed with departments for quality assurance and loss prevention purposes. The annual report must be posted from Feb 1 April 30. A claim is RECORDABLE under MIOSHA if: Medical care is received (beyond first aid) The claim results is days away or restricted days away from work MIOSHA Reporting Requirements: Employers are required to record work-related injuries or illnesses if they result in one of the following: death; days away from work; restricted work or transfer to another job; medical treatment beyond first aid; loss of consciousness. Employers are required to record cases as restricted work cases when the injured or ill employee only works partial days or is restricted from performing their "routine job functions" (defined as work activities the employee regularly performs at least once weekly). ( 1904.7(b)(4)). Employers are also required to record all needlestick and sharps injuries involving contamination by another person's blood or other potentially infectious material. ( 1904.8). Further, if a contracted worker receives dayto-day supervision by a U of M employee, any injury that is sustained by that worker must also be reported to Work Connections as it may meet the MIOSHA criteria to be included on the University s Log. Recordkeeping Process: Claims are coded and managed in RMIS-OASIS. Claim representatives have the responsibility to review injury coding and ensure its accuracy. In the event that a MIOSHA inspector comes on campus for routine or specific reviews a request is made for the most current log (though the log must be maintained for 5 years). The University, through Work~Connections, must provide the requested detail within 4 hours. Recordkeeping citations are rare and typically would require intent to mislead or misrepresent hazards in the workplace. 1 1 If an injury were not coded timely, or at all, a citation for failure to record could be issued. If recorded information lacks detail, a recording deficiency could be noted. Actions by MIOSHA would be stronger if the deficiency materially impairs the safety of the workplace. Employers would not be cited for misclassifying a claim and typically consequences would be issued only after an employer failed to adequately respond or correct recordkeeping problems. When appropriate, a penalty of $1000 (max of $3000) may be issued if OSHA 301(injury information) is not accurately completed.

Recordkeeping Compliance: Each year, the University posts the 300A Summary of Work-Related Injuries and Illnesses Log. This Summary is reported in four major groupings ( Establishments ): Ann Arbor Campus, Dearborn and Flint Campuses, and UMHHC. The Summary Log provides aggregate data within those groupings in the following categories: Number of Cases Number of Days Injury and Illness Types Employment Information (average number of employees and total hours worked). Specific claim detail is managed and distributed at the recharge and department levels, as well. Log Certification: The highest ranking official with oversight responsibilities for the function of MIOSHA Recordkeeping Compliance for the University of Michigan signs and certifies the four specific Injury and Illness data sets: Ann Arbor Campus, Dearborn Campus, Flint Campus and UMHHC. Establishment Reporting Employment Information Posting The log is certified in January. The Summary Log is reported in 4 primary areas ( MIOSHA Establishments ): Dearborn, Flint, Hospital and Health Centers and AA Campus. The Log requires employment information to be reported: Average number of employees Number of hours worked Summary logs are mailed and distributed electronically (W~C website and 3D broadcasts); MIOSHA requires the Summary Log be posted from Feb 1 April 30. Employment Information Queries are Pathways-based for the Ann Arbor, Dearborn and Flint data sets. UMH data relies upon two systems: Pathways and UMHHC DataMart. Communications and Postings: Mailed and electronically broadcast communications are widely distributed the last week in January each year, alerting supervisors, managers, directors and department heads of the University s obligation to report and post injury and illness summary data. Specific claim detail is also mailed out to departments and a register is maintained to track where logs have been posted for the Ann Arbor Campus establishment. The Summary Log is available from February 1 April 30 on the Work~Connections website. A central point of contact has also been communicated to departments to facilitate questions and other inquiries: Work~Connections Attention: Patty Harkiewicz (734) 615-2079 pharkiew@umich.edu