OSHA’s New Recordkeeping Standard

1. OSHA’s New Recordkeeping Standard Gayle W. Fratto Manager, Safety Engineering Branch

2. Why is OSHA Recordkeeping Important?? • Provides information to employers & employees on injuries/illnesses & related hazards in their workplaces • Employers: Management tool for administration of company safety & health programs • Employees: Raises awareness level • Provides OSHA compliance staff with information to facilitate inspections • Produces statistical data, thereby measuring magnitude of nation's injury & illness problem

3. OSHA VS. WRKR. COMP. • OSHA RECORDKEEPING REQUIREMEENTS ARE NOT THE SAME AS WORKER’S COMPENSATION REQUIREMENTS!!!!

4. New Forms • 300 Log • 301 Supplemental Form • 300A Summary

5. Recording Criteria • Injuries and Illnesses • Work Related • New Case • Meet one or more of Gen. Requirements • Additional Criteria

6. Additional Recording Criteria • Needlestick and Sharp • Tuberculosis • Hearing Loss • Medical Removal • MSD Cases

7. Exceptions to Work Environment • EE member of the general public • Symptoms at work but source isn’t • Results voluntarily from wellness/recreation programs • Eating/Preparing foods • Performing personal tasks outside of normal work hours • Personal grooming, self medication (for non work related illness), self inflicted. • Motor vehicle accident in co. parking lot • Common cold/flu

8. Exceptions (continued) • Common cold/flu • Mental Illness

9. Travel Status • Hotel • Detours

10. General Recording Criteria • For Injuries and Illnesses • Death • Loss of consciousness • Lost work day • Restricted work time/Job transfer • Medical treatment • Significant injury or illness diagnosed by physician or licensed health care professional

11. Lost Work Days • Count Calendar Days • Doctor/Licensed Health Care Provider’s Opinion • Counting Cap – 180 days

12. Restricted Work Days/Job Transfer • Count Calendar Days • Capp – 180 Days • Permanent Transfer

13. Medical Treatment - Exceptions • Visits to Medical Professional Solely for Medical Observation • First Aid – (ex. Butterfly Dressings) • Diagnostic Procedures • Prescription Medication (ex. eyes drops)

14. First Aid • Enclosed list of First Aid Treatments • No other treatment!

15. Significant Diagnosed Injury or Illness • Diagnosed by Physician or Licensed Health Care Specialist • Cancer • Chronic Irreversible Disease • Fractured or Cracked Bone (ex. Broken Toe, Broken Rib) • Punctured Eardrum

16. Hearing Loss • STS of 10db or more at 2000, 3000, and 4000 htz. • Adjusted for Age • Retesting – STS not Recorded if New Test Performed Within 30 days (with negative results)

17. Recording • Within 7 Calendar Days • Centralized Records • Recorded within 7 calendar days • Make copies available • Employees • Former employees • Government Reps. • Employees Reps

18. Privacy Concern • “Privacy Case” – In Place of EE Name • Injury or illness to intimate part of the body • Sexual assault • Mental illness • HIV, hepatitis, tuberculosis • Contaminated needlestick/sharps cut • Other illness – If employee voluntarily requests it

19. Privacy Concern (cont.) • No Other Cases Classified as Privacy Case • Additional – Allowed Discretion in Describing Injury

20. 300A - Summary • Separate Page • February 1, through April 30 • Signed by Company Executive • Company Owner – If sole proprietorship • Officer of Corporation • Highest ranking company official at worksite • Immediate supervisor of the highest ranking company official at the establishment

21. 300 Disclosure • Disclosed by the End of the Next Business Day • Employee or Former Employee • Authorized Rep. • Personal Rep. • Designated by the employee or former employee in writing • Legal rep. of a deceased or mentally incapacitated employee or former employee

22. 301 Disclosure • Within 7 Calendar Days • Authorized employee rep. • Only supply section entitled “Tell Us About the Case” • Next Business Day • Personal rep. • Employee or former employee

23. Retain/Maintain • 300, 301, 300A Must be Retained for 5 Years Minimum • 300 Must be Maintained for the 5 Years

24. Other Reporting • Fatalities/Mass Hospitalization (3 or More Employees) • Reported orally (to the Area Office nearest the incident) • Must be reported within 8 hours • Central number – 1-800-321-0SHA

25. Other Reporting (cont.) • Exception (Fatality/Mass Hospitilization) • Motor vehicle accident on public street or highway. • Public Transportation • More than 30 days past accident • Still needs to be recorded

26. Government Representatives • Required to Supply Copies of Records • Must Be Supplied Within 4 Business Hours • Reps. Include: • Rep. of Secretary of Labor • Rep. of Secretary of Health and Human Services (including NIOSH) conducting and investigation • Rep. of State agency responsible for admin. of state plan