Highlights of OSHA’s Recordkeeping Rule

1. Highlights of OSHA’s Recordkeeping Rule Courtney W. Bohannon Jackson Area Office

2. Recordkeeping Highlights • Updates the three recordkeeping forms: • OSHA form 300 • OSHA form 301 • OSHA form 300A

3. Recordkeeping Highlights • Requires records to include any work-related injury or illness resulting in one of the following; • Death; • Days away from work; • Restricted work; • Medical treatment;

4. Recordkeeping Highlights • Recordability (cont’d): • Loss of consciousness; • Diagnosis of a significant injury/illness

5. 1904.7(b)(5) – First Aid • Using nonprescription medication at nonprescription strength • Tetanus immunizations • Cleaning, flushing, or soaking surface wounds • Wound coverings, butterfly bandages, Steri-Strips • Hot or cold therapy • Non-rigid means of support • Temporary immobilization device used to transport accident victims

6. First Aid • Drilling of fingernail or toenail, draining fluid from blister • Eye patches • Removing foreign bodies from eye using irrigation or cotton swab • Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means • Finger guards • Massages • Drinking fluids for relief of heat stress

7. To records or not record? • Second or subsequent hot and cold soaks and use of whirlpool treatment. • Not Recordable

8. To records or not record? • One-time administration of oxygen for several minutes. • Recordable

9. To records or not record? • Employee has work-related elbow pain and is given non-prescription pain medication at prescription strength. • Recordable

10. Recordkeeping Highlights • Adds additional exemptions to the definition of work-relationship.

11. Job Restriction • Restricted work activity occurs when: • An employee is kept from performing one or more routine functions (work activities the employee regularly performs at least once per week) of his or her job; or • An employee is kept from working a full workday; or • A PLHCP recommends either of the above

12. 1904.7(b)(4) – Job Transfer • An injured or ill employee is assigned to a job other than his or her regular job for part of the day • A case is recordable if the injured or ill employee performs his or her routine job duties for part of a day and is assigned to another job for the rest of the day

13. Recordkeeping Highlights • Eliminates the term "lost workdays" and focuses on days away or days restricted or transferred. • Cap day count at 180 days.

14. Recordkeeping Highlights • Requires recording of all needlestick and sharps injuries involving contamination by another person's blood or other bodily fluids.

15. Recordkeeping Highlights • Provisions describing the recording criteria for cases involving the work-related transmission of tuberculosis or medical removal under OSHA standards.

16. Recordkeeping Highlights • Establish a procedure for employees to report injuries and illnesses and tell their employees how to report.

17. Recordkeeping Highlights • Protects employee privacy

18. Recordkeeping Highlights • 3 month posting. • Certify.

19. Recordkeeping Highlights • Changes the reporting of fatalities and catastrophes to exclude some motor carrier and motor vehicle accidents.

20. Record Access • Must provide limited access to injury and illness records • Must provide copies of the records within 4 business hours • Use the business hours of the establishment where the records are located

21. Entering Information on the OSHA 300 Log • 1/23/02, Allen Ghouleah, Welder in Welding Department, developed flash burn in both eyes. Received prescription medication. No days away from work. • Recordable {1904.7(b)(5)}, Other Recordable Cases, All other illnesses.

22. Entering Information on the OSHA 300 Log • 2/1/02, Shawn Hogal, Maintenance Supervisor in Maintenance Department working in the boiler room. Found unconscious in boiler. Sent to hospital where he died 2/3/02. Diagnosis was death due to carbon monoxide. • Recordable, Death, Poisoning.

23. Entering Information on the OSHA 300 Log • 3/6/02, Bob Foglia, Shipping Department Forklift Operator. Broke his right large toe, when the forklift ran over his foot. Unable to walk but was able to drive the forklift. Had another employee do work for him which required walking for 4 days. No days away from work. • Recordable, Job Restriction, Injury (4 days job restriction)

24. Entering Information on the OSHA 300 Log • 3/9/02, Marilyn Rose, Canning Machine Operator in Canning Department. Foreign object in right eye (not embedded). Doctor said she could return to work but Marilyn did not return for 2 days because of eye pain. • Not Recordable

25. Entering Information on the OSHA 300 Log • 3/11/02 Carrie Nation, Maintenance Department. Employee is designated first aid responder reported that she received a needle stick to the left hand while cleaning up the Canning Area contaminated with Mark Boulware’s blood after the EMS team removed Mark. There was a recommendation for medical treatment. • Recordable, Other recordable cases, Injury-Privacy Case.

26. Entering Information on the OSHA 300 Log • 6/21/02 Cathy Withmore, Computer Operator in the Training Department, choked on a sandwich in the lunchroom. Hospitalized for 2 days. • Not Recordable {1904.5(b)(2)(iv)}.

27. Entering Information on the OSHA 300 Log • 7/15/02 Valerie Gilmore, retired Boiler Room Supervisor (4 years ago), after working 40 years. She was diagnosed with work related asbestosis. • Recordable, Other Recordable Cases, Respiratory Condition.

28. Entering Information on the OSHA 300 Log • 7/16/02 John Doe, Shop Foreman, had a diabetic incident that occurred while he was working. • Not Recordable {1904.5(b)(2)(ii)}.

29. Courtney W. Bohannon USDOL – OSHA Jackson Area Office 3780 I-55 North Suite 210 Jackson, MS 39211-6323 601-965-4606 ext. 35 bohannon.courtney@dol.gov