Brief Overview of OSHA’s Recordkeeping Rule

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

2. 1904.5 – Work-Relatedness • A case is considered work-related if an event or exposure in the work environment either caused or contributed to the resulting condition • A case is considered work-related if an event or exposure in the work environment significantly aggravated a pre-existing injury or illness • Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the workenvironment

3. 1904.5 – Work Environment • The workenvironment is defined as the establishment and other locations where one or more employees are working or present as a condition of employment • The work environment includes not only physical locations, but also the equipment or materials used by employees during the course of their work

4. 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;

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

6. 1904.7(b)(4)Restricted Work • 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

7. 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

8. 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

9. 1904.7(b)(5) – 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

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

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

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

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

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

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

18. Recordkeeping Highlights • Protects employee privacy

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

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

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

22. 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

23. Electronic Version of OSHA 300 & 300A

26. Electronic Version of OSHA 300 & 300A • If you would like a copy, e-mail me at: • bohannon.courtney@dol.gov • Type “e-300” in subject line

27. Activity #2: Entering Information

28. 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.

29. 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.

30. 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)

31. 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

32. 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.

33. 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)}.

34. 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.

35. 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)}.

36. 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

37. DISCLAIMER This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address recordkeeping, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute,

38. DISCLAIMER regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at www.osha.gov