OSHA INJURY AND ILLNESS RECORDKEEPING

1. OSHA INJURY AND ILLNESS RECORDKEEPING

2. WARNING: DO NOT MIXOSHA RECORDABILITY AND WORKERS’ COMPENSATION • Workers’ Compensation determinations do NOT impact OSHA recordability. Some cases may be OSHA recordable and compensable. Some cases may be compensable, but not OSHA recordable. Some cases may be OSHA recordable, but not compensable.

3. Organization of the Rule • Subpart C - Forms and recording criteria • Subpart D - Other requirements • Subpart E - Reporting to the government • Subpart G - Definitions

4. Recording Criteria • Subpart C - Recordkeeping Forms and Recording Criteria • 1904.4 Recording criteria • 1904.5 Work-relatedness • 1904.6 New case • 1904.7 General recording criteria • 1904.8 Needlesticks and sharps • 1904.9 Medical removal • 1904.10 Hearing loss • 1904.11 Tuberculosis • 1904.29 Forms

5. 1904.4 – Recording Criteria Covered employers must record each fatality, injury or illness that: • Is work-related, and • Is a new case, and • Meets one or more of the criteria contained in sections 1904.7 through 1904.11

6. OSHA INJURY AND ILLNESS RECORDKEEPING 5 STEP PROCESS

7. Is the injury or illness work-related? Is the injury or illness a new case? Did the employee experience an injury or illness? YES YES YES Does the injury or illness meet the general criteria or the application to specific cases? YES Record the Injury or illness.

8. Step 1: Did the employee experience an injury or illness? Definition An injury OR illness is an abnormal condition or disorder. Injuries include cases such as, but not limited to, a cut, fracture, sprain, or amputation. Illnesses include both acute and chronic illnesses, such as, but not limited to, a skin disease, respiratory disorder, or poisoning.

9. Step 1: Did the employee experience an injury or illness? Scenario A: A worker reports to nurses station with complaint of painful wrists. Employee given 2 Advil™ and returned to job. Stop Here OR Go On To The Next Step? Answer: Go on to the next step. Why:Painful wrists was the injury experienced.

10. Step 1: Did the employee experience an injury or illness? Scenario B: There is a chlorine gas leak at XYZ establishment and the two (2) employees in the area are rushed to the hospital. They are told to stay home the next day as a precautionary measure. Stop Here OR Go On To The Next Step? Answer:It depends ! ! We need more information. Why:We need to know if either employee exhibited signs or symptoms of an injury/illness. If yes, then go to the next step. If no, STOP. We have an event or exposure only.

11. Is the injury or illness work-related? Did the employee experience an injury or illness? YES

12. Step 2: Is the injury or illness work-related? Determination of work-relatedness You must consider an injury or illness to be work-related if an identifiable event or exposure (i.e., discernable cause) in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures in the work environment unless an exception specifically applies.

13. 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

14. The following situations are not work-related: 1. There is nodiscernable cause. Injury/illness did not result from event/exposure at work • At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee. • The injury or illness involves signs or symptoms that surface at work but result solely from a non-work related event or exposure that occurs outside the work environment. • The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball. • The injury or illness is solely the result of an employee eating, drinking, or preparing food or drinkfor personal consumption (whether bought on the employer’s premises or brought in). For example, if the employee is injured by choking on a sandwich while in the employer’s establishment, the case would not be considered work-related. Note: If the employee is made ill by ingesting food contaminated by workplace contaminants (such as lead), or gets food poisoning from food supplied by the employer, the case would be considered work-related.

15. The following situations also are not work-related: • The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee’s assigned working hours. • The injury or illness is solely the result of personal grooming, self medication for a non-work-related condition, or is intentionally self-inflicted. • The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work. • The illness is the common cold or flu (Note: contagious diseases such as tuberculosis, brucellosis, hepatitis A, or plague are considered work-related if the employee is infected at work). • The illness is a mental illness. Mental illness will not be considered work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related.

16. 1904.5 – Work RelationshipPre-Existing Conditions A “Pre-existing” condition - an injury or illness that resulted solely from a non work- related event or exposure that occurred outside of the work environment A pre-existing injury or illness is significantly aggravated when the following cases would not have occurred but for an event or exposure in the work environment: • Death • Loss of Consciousness • Days Away, Days Restricted or Job Transfer • Medical Treatment

17. Step 2: Is the injury or illness work-related? Scenario A: Employee gives blood at voluntary employer sponsored blood drive and passes out – losses consciousness. Stop Here OR Go On To The Next Step? Answer: Stop Here Why?: Exception #4 - The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball.

18. Step 2: Is the injury or illness work-related? Scenario B: Employee sprains ankle in company parking lot on their way in to work. Stop Here OR Go On To The Next Step? Answer: Go on Why?: There is no exception that applies.

19. Step 2: Is the injury or illness work-related? Scenario C: Employee slips and falls in hallway, breaking arm while working on daughter’s science project on Saturday, employee’s day off. Stop Here OR Go On To The Next Step? Answer: Stop Why?: Exception #6 - The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee’s assigned working hours.

20. Is the injury or illness work-related? Is the injury or illness a new case? Did the employee experience an injury or illness? YES YES

21. Step 3: Is the injury or illness a new case? Determination of a new case Consider an injury or illness a “new case” if the employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body, OR the employee previously experienced a recorded injury or illness of the same type that affected the same part of body but had recovered completely (all signs and symptoms had disappeared) from the previous injury or illness and an event or exposure in the work environment caused the signs or symptoms to reappear.

22. Step 3: Is the injury or illness a new case? Scenario A: Five (5) weeks ago, employee sprained wrist at work and received support, prescription medication, and “light duty.” Two weeks ago employee was back on normal job. Today (5 weeks after the injury) employee complains of pain in same wrist after moving boxes. Stop Here OR Go On to the Next Step? Answer: Go on Why?:Employee was back at normal job and no criteria for recordability was in existence at that time.

23. Step 3: Is the injury or illness a new case? Scenario B: Five (5) weeks ago employee sprained wrist at work and received support, prescription medication, and “light duty”. Two weeks ago employee was back on normal job. Today (5 weeks after the injury) employee complains of pain in same wrist after moving boxes. Employee continues to take prescription medications for pain throughout this period of time. Stop Here OR Go On to the Next Step? Answer: Stop Why?:Update the previously recorded injury or illness entry if necessary.

24. Step 3: Is the injury or illness a new case? • Scenario C: Employee fractures foot at work. Every six months or so it bothers him and he is placed on light duty for a day or two. Stop Here OR Go On to the Next Step? Answer:It depends. We need more information Why?:Was the employee completely recovered. If no stop. If yes, was there a new event or exposure in the work environment.

25. Is the injury or illness work-related? Is the injury or illness a new case? Did the employee experience an injury or illness? YES YES YES Does the injury or illness meet the general criteria or the application to specific cases?

26. Step 4: Does the injury or illness meet the general criteria or the application to specific cases? General Recording Criteria You must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. You must also consider a case to meet the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.

27. DAY COUNTS Count the number of calendar days the employee was away from work or restricted/transferred (include weekend days, holidays, vacation days, etc.) May cap day count at 180 days away from work and/or days of restricted/job transfer Maystop day count if employee leaves company for a reason unrelated to the injury or illness. Mustestimate day count when employee leaves company due to reasons related to the injury and illness

28. Restricted Work Activity • Restriction/transfer limited to day of injury/illness onset not recordable-includes employee being sent home during shift. • Production of fewer goods or services not considered RWA • Vague restrictions from physician or PLHCP (e.g., “light duty” or “take it easy for a week”) are to be recorded as RWA if no further information is obtain. • A case is not recordable if the employee experiences minor musculoskeletal discomfort, a health care professional determines that the employee is fully able to perform all of his or her routine job functions, and the employer assigns a work restriction to that employee for the purpose of preventing a more serious condition from developing. Once a case becomes recordable under section 1904.7 general recording criteria, the discomfort is no longer minor.

29. 1904.7 – Job Transfer • Injured or ill employee assigned to job other than regular job for part of the day • Do not include day of injury/illness onset • record job transfer day (s) in RWA column • Stop count when transfer permanent-- BUT MUST COUNT AT LEAST ONE DAY

30. Medical Treatment VS First Aid Medical treatment DOES NOT include: 1. Visits to a physician or other licensed health care professional solely for observation or counseling only 2. Diagnostic procedures such as x-rays and blood tests, including administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils) 3. First Aid

31. Medical Treatment VS First Aid – cont’d. First Aid list in regulation is comprehensive. Any other procedure is medical treatment. • Using temporary immobilization devices while transporting an accident victim is First Aid - Drilling a nail is First Aid • Using eye patches is First Aid • Removing foreign bodies from the eye using only irrigation or a cotton swab is First Aid • Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means is First Aid • Using finger guards is First Aid • Using massages is First Aid -Drinking fluids for relief of heat stress is First Aid

32. Medical Treatment VS First Aid – cont’d. • Using any non-rigid means of support, as elastic bandages, wraps, back belts, etc. is First Aid • 1 dose prescription medis Medical Treatment • Over the Counter non-prescription med at non-prescription strength is First Aid • OTC med at prescription strengthis Medical Treatment • Ibuprofen (such as Advil™) - Greater than 467 mg Diphenhydramine (such as Benadryl™) – Greater than 50 mg Naproxen Sodium (such as Aleve™) – Greater than 220 mg Ketoprofen (such as Orudus KT™) – Greater than 25 mg • Administering tetanus immunizations is First Aid • Cleaning, flushing or soaking wounds on the surface of the skin is First Aid • Using wound coverings such as Band-Aids; Butterfly bandage/Steri-Strip (the only kind of wound closures) are First Aid • Any number of hot-cold treatments is First Aid

33. Significant diagnosed Injury or Illness that is automatically recordable if work related: 1. Fracture 2. Punctured ear drum 3. Cancer 4. Chronic irreversible disease (e.g., silicosis)

34. Is the injury or illness work-related? Is the injury or illness a new case? Did the employee experience an injury or illness? YES YES YES Does the injury or illness meet the general criteria or the application to specific cases? YES Record the Injury or illness.

35. Determining CaseSeverityCase Scenarios Employee has a work-related injury or illness, sees doctor, told she can only work on light duty for the next two weeks. Normally scheduled for five day workweeks. How many days of restricted work activity should be entered on the OSHA Log?

36. Determining Case RecordabilityCase Scenarios • If a physician recommends medical treatment, but the employee does not follow the recommendation, is the case recordable? • If an injured employee has repeated sessions of hot or cold therapy, does this case involve medical treatment? • Wound closures : Steri-Strips and butterfly bandages are now considered to be first aid. Does this mean that staples, surgical glue, or other wound closures are also first aid?

37. Determining Case RecordabilityCase Scenarios • Employee receives prescription medication in her eye to facilitate examination. Is this considered medical treatment? • Employees exposed to slight release of non toxic chemical. Several feel “light headed”, receive simple administration of oxygen and return to work. Are these cases recordable? • Employee’s ankle is injured at work; a slight hairline fracture is detected in a positive X-ray diagnosis. No medical treatment is provided. Is this case recordable?

38. 1904.8 – Bloodborne Pathogens • Record all work-related needlesticks and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material (includes human bodily fluids, tissues and organs; other materials infected with HIV or HBV such as laboratory cultures) • Record splashes or other exposures to blood or other potentially infectious material if it results in diagnosis of a bloodborne disease or meets the general recording criteria

39. Relationship to Bloodborne Pathogen Standard • Employers may elect to use the OSHA 300 and 301 forms to meet the sharps injury log requirements, provided two conditions are met: • The employer must enter the type and brand of the device on either the 300 or 301 form. • The employer must maintain the records in a way that segregates sharps injuries from other types of work-related injuries and illnesses, or allows sharps injuries to be easily separated.

40. 1904.9 – Medical Removal • If an employee is medically removed under the medical surveillance requirements of an OSHA standard, you must record the case • The case is recorded as either one involving days away from work or days of restricted work activity • If the case involves voluntary removal below the removal levels required by the standard, the case need not be recorded

41. Conditions For Hearing Loss Recordability 1904.10 OSHA’s recordkeeping rule requires the employer to record all work- related hearing loss cases that meet BOTH of the following conditions on the same audiometric test for either ear: • The employee has experienced a Standard Threshold Shift (STS) – 10dB or greater from the most current baseline. • The employee’s total hearing level is 25 dB or more above • audiometric zero (averaged at 2000, 3000, & 4000 Hz) in the • same ear(s) as the STS.

42. Has the employee suffered a STS (an average 10dB or more loss relative to the most current baseline audiogram averaged at 2000, 3000 and 4000 Hz) in one or both ears according to the provisions of the OSHA noise standard (§1910.95)? * Is the employee’s overall hearing level at 25dB or more above audiometric zero averaged at 2000, 3000 and 4000 Hz in the affected ear(s)? Is the hearing loss work-related? Record on the OSHA 300 Log,and check the column “All other Illnesses” ** Do not record Use this ‘decision tree’ to determine whether the results of a audiometric exam given on or after January 1, 2003 reveal a recordable STS. No Yes No Yes No Yes Note: In all cases, use the most current baseline to determine recordability as you would to calculate a STS under the hearing conservation provisions of the noise standard (§1910.95). If an STS occurs in only one ear, you may only revise the baseline audiogram for that ear. * The audiogram may be adjusted for presbycusis (aging) as set out in 1910.95. * A separate hearing loss column on the OSHA 300 Log beginning in Calendar year 2004. .

43. 1904.11 - Tuberculosis • Record a case where an employee is exposed at work to someone with a known case of active tuberculosis, and subsequently develops a TB infection • A case is not recordable when: • The worker is living in a household with a person who is diagnosed with active TB • The Public Health Department has identified the worker as a contact of an individual with active TB • A medical investigation shows the employee’s infection was caused by exposure away from work

44. Musculoskeletal Disorders Record all work-related MSD cases that meet any of the general recording criteria. Depending upon the nature of the event or exposure that causes the case you should record these cases as an injury or an “all other illness”

45. 1904.29 - Forms • OSHA Form 300, Log of Work-Related Injuries and Illnesses • OSHA Form 300A, Summary of Work-Related Injuries and Illnesses • OSHA Form 301, Injury and Illness Incident Report

48. 1904.29 - Forms • Employers must enter each recordable case on the forms within 7 calendar days of receiving information that a recordable case occurred • An equivalent form has the same information, is as readable and understandable, and uses the same instructions as the OSHA form it replaces • Forms can be kept on a computer as long as they can be produced when they are needed (i.e., meet the access provisions of 1904.35 and 1904.40)

49. 1904.29 – Privacy Protection • Do not enter the name of an employee on the OSHA Form 300 for “privacy concern cases” • Enter “privacy case” in the name column • Keep a separate confidential list of the case numbers and employee names

50. 1904.29 – Privacy Protection • Privacy concern cases are: • An injury or illness to an intimate body part or reproductive system • An injury or illness resulting from sexual assault • Mental illness • HIV infection, hepatitis, tuberculosis • Needlestick and sharps injuries that are contaminated with another person’s blood or other potentially infectious material • Employee voluntarily requests to keep name off for other illness cases