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Injury & Illness Recording (Update 2005). Marianne McGee. Forms. Updates three recordkeeping forms OSHA Form 300 – Log of Work-Related Injuries and Illnesses OSHA Form 301 – Injury and Illness Incident Report OSHA Form 300A – Summary of Work-Related Injuries and Illnesses. 1904.29.
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Injury & Illness Recording(Update 2005) Marianne McGee
Forms • Updates three recordkeeping forms • OSHA Form 300 – Log of Work-Related Injuries and Illnesses • OSHA Form 301 – Injury and Illness Incident Report • OSHA Form 300A – Summary of Work-Related Injuries and Illnesses 1904.29
Work-Relatedness • Cases are work-related if: • An event or exposure in the work environment either caused or contributed to the resulting condition • An event or exposure in the work environment significantly aggravated a pre-existing injury or illness 1904.5
Work-Related Exceptions • Cases not work related: • Employee present as a member of the general public • Non-work event or exposure (e.g. asthma or diabetes) • Eating and drinking of food and beverages • Voluntary Wellness Programs or Blood Donations • Personal tasks outside of working hours. 1904.5(b)(2)
Work-Related Exceptions • Cases not work related: • Self grooming or self medication • Common colds and flu • Motor Vehicle Accidents: • In company parking lot/access road • On commute to or from work • Mental Illnesses 1904.5(b)(2)
General Recording Criteria • Requires records to include any work-related injury or illness resulting 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 • Diagnosis of a significant injury/illness by a physician or other licensed health care professional 1904.7(a)
General Recording Criteria (continued) • Medical treatment vs first aid • “Light duty” or restricted work cases Medical Treatment First Aid 1904.7(b)(5)
Day Counts • Focuses on days away or days restricted or transferred • Count calendar days instead of workdays 1904.7(b)(3)
Fatalities • All work-related fatalities must be reported to the local OSHA office (or 800-321-OSHA) within 8 hours. • Heart attacks included • Vehicle accidents don’t need to be REPORTED to OSHA (but may be recordable)
Annual Summary • Annual summary posted for three months • Certification of the summary by a company executive 1904.32
Retention & Updating • Keep current year plus previous 5 years data. • OSHA 300 Log • OSHA 301 Supplemental Form • Privacy Case List (If Applicable) • During storage period, you must update stored records.
Recordkeeping Webpage Save the PDF file to your hard drive
Would an injury be recordable if: • An employee suffered a recordable injury but the employee had a positive drug test and was fired? • Yes – CPL 2-0-135 Question 7-9 (when the employer conducts a drug test based on the occurrence of an accident resulting in an injury at work and subsequently terminates the injured employee, the termination is related to the injury)
Would an injury be recordable if: • An employee is working in the field and is assaulted by illegal aliens. • Yes – CPL 2.0.135 Question 5-2 • Also, use the “but for test”. But for the fact the employee was working, the incident would not have occurred.
Would an injury be recordable if: • An employee is turning a wrench and it slips off and hits and breaks (or cracks) a tooth. • Yes – CPL 2-0-135 Question 7-17 page 40-41. (Work-related fractures of bones or teeth are recognized as constituting significant diagnoses and, if the condition is work-related, are appropriately recorded at the time of initial diagnosis even if the case does not involve any of the other general recording criteria)
Would an injury be recordable if: • An employee damaged a prosthetic such as a leg or tooth. • Yes – because medical treatment would normally be required to repair the prosthetic.
Would an injury be recordable if: • An employee is injured and receives medical treatment, • A second opinion is obtained and states medical treatment was not necessary? Yes, CPL 2-0-135 Question 7-10a page 39 (In the case of prescription medications, OSHA considers that medical treatment is provided once a prescription is issued)
Would an injury be recordable if: • An employees suffers a cut and medical glue is used in lieu of stitches. • Yes - CPL 2-0-135 Question 7-5 page 37 (Surgical glue is a wound closing device. All wound closing devices except for butterfly and steri strips are by definition "medical treatment," because they are not included on the first aid list)
Would an injury be recordable if: • An employee dies during surgery made necessary by a work-related injury? • Yes, CPL 2-00-135 Question 7-3, page 37. (If an employee dies as a result of surgery or other complications following a work-related injury or illness, the case is recordable)
Would an injury be recordable if: • An employee is involved a fatal vehicle accident in a foreign country? • No – Letter of Interp. 8/26/2004. Only if the incident is in the jurisdiction of OSHA (US, DC, Puerto Rico, Virgin Islands, Outer Continental Shelf Lands)
Would an injury be recordable if: • An employee is injured at work and the physician gives a prescription medication but the employee does not take the medicine? • One dose? • Yes, CPL (Once medical treatment is provided for a work-related injury or illness, or days away from work or work restriction have occurred, the case is recordable. OSHA considers that medical treatment is provided once a prescription is issued)
Would an injury be recordable if: • An employee is injured at work and the physician tells the employee to take an over-the-counter medicine • The employee has a reaction and as a result has to take a prescription? • Yes, but for the fact the employee had a work-related injury they would not have taken the OTC.
Would an injury be recordable if: • An employee was stung by a bee, and due to a severe allergic reaction the employee carries and administers an epi-pen? • Yes, “but for” the employee being in the work environment he would not have received the sting.
Would an injury be recordable if: • An employee is on-call and is injured while responding. • Yes – except for one commute. • At a drill site, employee sleeps in a trailer but would be expected to respond to an alarm. As soon as the alarm sounds, work status begins.
Would an injury be recordable if: • Volunteer fire brigade member goes for an annual physical. • Phlebotomist is rough while drawing blood. • The following day the ees arm has red streaks. • The Doctor prescribes an RX. • Recordable?