OSHA Recordkeeping

1. OSHA Recordkeeping

2. An employer who had no more than 10 employees at any time Hardware stores Meat & fish markets Eating & drinking places Liquor stores Insurance carriers Apparel & Accessory Stores New and Used Car Dealers Gasoline service stations Real estate agents Photographic studios Reupholster & furniture repair Radio, t.v. & computer stores Offices & clinics of MD’s, Dentists, other Health practitioners Medical & dental labs Legal services Educational services Child day care services Museums & art galleries Motion picture Producers, orchestras, entertainers Bowling centers Advertising services Credit reporting & collection services Beauty & barber shops Does This Standard Apply to You? (Partially Exempt Industries)

3. State Programs Check your own state program for recordkeeping requirements.

4. What are the Recordkeeping & Reporting Requirements? • If you are covered under Federal OSHA you must keep these records or report the following: • OSHA Form 300 “Log” • OSHA Form 300A “Summary” • OSHA Form 301 or equivalent • Fatalities • Hospitalization of 3 or more employees • All fatal heart attacks that occur in the work environment • Please check your state program if applicable.

5. What’s Recordable? • Fatality. • Loss of consciousness. • Days away from work. • Restricted or light duty work as ordered by a health provider. • Any work injury or illness that is significant. • Medical treatment (see next slide). • Prescription medication ordered (even if it is over the counter medication given at prescription levels).

6. Medical Treatment • Diagnostic test with positive findings (i.e., positive x-ray, CT scan). • Usually includes admission to a hospital. • Sutures are given. • Therapy is given or prescribed. • Using a derma-bond to close a wound. • Rigid supports, splints

7. Other Recordable Criteria • Needle stick injuries or cut from sharp object contaminated with blood or OPIM’s (other potentially infectious materials). • A situation where an employee has to be medically removed under OSHA’s health standards. • TB per a “+” skin test, physician diagnosis or exposure to known case of active TB. • Employee audiogram reveals standard threshold shift in one or both ears and total hearing level is 25 dB or more above audiometric zero. • Note: Other infectious diseases: • To be recordable, it must fit recordable criteria. • Exposure alone is not recordable; exposure must cause a “+” test result. • Follow-up on cases to see if exposure caused “+” test outcomes.

8. What’s Not Recordable • Visit to a provider solely for observation or evaluation. • Diagnostic tests with negative findings. • First aid is given (see next slide). • Non-prescription or over-the-counter medications are given. • Accident/illness occurred outside the course of work.

9. Tetanus shot Cleaning, flushing, soaking surface wound Wound coverings (butterfly, bandage, steri-strips Hot/cold therapy Non-rigid support (wrap) Temp. immobilization device used to transport employee Drilling finger/toe nail Draining blister Eye patch Remove foreign body from eye with swab, irrigation Remove foreign body from skin with tweezers, swab, irrigation etc. Finger guard Massage Drink fluids for heat stress relief Using type liquid bandage to cover a wound First Aid

10. OSHA’s Form 300 “Log”How to Complete • First complete establishment’s name & location in the upper right of the log. • Column A (case number). This is usually done in numeric order. • Column B (employee name).

11. Do Not Put Name on Log When… (Column B) • Injury/illness to reproductive part or intimate body part. • Injury/illness from sexual assault. • Mental illness. • Case of HIV, TB or hepatitis. • Needle stick injury or cut from sharp object that is contaminated with blood or OPIM’s. • If employee independently & voluntarily requests their name not be on the log. • Instead enter “privacy case” where the name would usually go on the 300 Log. • You must then keep a separate, confidential list of the case numbers & employees’ names.

12. OSHA’s Form 300 “Log”How to Complete • Column C (job title). • Column D (date of injury or illness onset). • Column E (where the incident occurred).

13. OSHA’s Form 300 “Log”How to Complete • Column F (describe injury or illness). • Classify the case (columns G, H, I, J): • Choose only one of these categories • Record the most serious outcome of each incident: • For example, if the employee missed 2 weeks of work per physician’s orders and then was on light duty for 1 week, record this as “days away from work” as this is more serious than light duty for one week.

14. OSHA’s Form 300 “Log”How to Complete • Next complete how many days the employee was away from work or did work but with a job transfer or restriction (columns K, L): • Count calendar days, not only the days the worker was scheduled to work. • Do not count the date of injury. • Complete both columns if applicable.

15. OSHA’s Form 300 “Log”How To Complete • Column M 1-6 (check whether the incident was an injury or choose which illness). • Make sure to put totals at the bottom of all columns when the page is full and/or at the end of the calendar year.

16. Injuries: Cut Puncture Laceration Abrasion Fracture Bruise Contusion Chipped tooth Amputation Insect bite Electrocution Radiation burn Sprains/strains (from slip,trip, fall Illnesses: Skin disease or disorder Respiratory conditions Poisoning Hearing Loss Other: Effects environmental heat or cold Decompression sickness Ionizing and nonionizing radiation Anthrax BBP disease Tumors Brucellosis Histoplasmosis OSHA’s Form 300 “Log”Classifying Injuries vs. Illnesses

17. OSHA’s Form 300 “Log”Other Notes • Each recordable case must be recorded within 7 calendar days of receiving the information. • If the outcome changes after the entry: • Draw a line through the entry OR • Delete the entry OR • White-out the entry • Re-record the incident where it belongs • Stop counting days when it exceeds more than 180 days (enter “180” or “180+”). • Can include days away from work, restricted/alternate work days, or a combination of both.

18. OSHA’s Form 300 “Log” Other Notes • If your company has multiple sites keep separate records for each physical location (that is in operation 1 year or longer). • Cases that carryover to the next year: • Example: Employee is hurt on December 29th and is away from work until January 10th. • You only need to record this case once (the year it occurred). • If the employee is still away when summary is prepared (before Feb. 1st) either count the number of days employee was away or estimate total days away that are expected. • Update the Log entry later when the actual number of days is known (or the case reaches the 180-day cap).

19. OSHA’s Form 300A Summary • Transfer totals of columns G – M from the 300 Log onto the corresponding spaces of the 300A Summary. • Make sure to include all employees that were: • Full-time • Part-time • Temporary • Seasonal • Salaried • Hourly

20. OSHA’s Form 300A Summary • Complete Establishment section. • Complete Employment section: • Please refer to the Summary worksheet if you need assistance completing: • average number of employees • total hours worked • Complete the signature section: • Ensure a top company executive signs the Summary.

21. OSHA’s Form 300A Summary - Posting • The 300A Summary is posted Feb. 1 through April 30th of the next calendar year (example: the summary for 2007 is posted Feb. 1 through April 30th 2008). • You do not post the 300 Log. • Post the 300A Summary in a visible location.

22. Recordkeeping for Contracted Employees • If you have contracted employees: • Injuries and illnesses are counted on the 300 log and summary • Include their work hours in the summary • Exception: if the contracted company has their own management on-site you do not need to count their injuries/ illnesses or work hours: • Example: Company A has hired Ajax Cleaning to do housekeeping in the facility. Ajax has their own supervisor on-site. Ajax then is responsible for their own recordkeeping.

23. For 300 & 300A Forms • Even if there were no cases for a calendar year, there still must be a Form 300 and 300A completed. • Put “zero” in the columns if this is the outcome – don’t leave columns blank.

24. OSHA’s Form 301Incident Report • Each recordable case must be recorded within 7 calendar days of receiving the information. • Some state’s Worker’s Compensation, insurance or similar reports may be acceptable substitutes (example: IL Form 45). • Substitute forms must contain all the information as Form 301 requests.

25. How Long Do You Keep Records? • You must keep the current year’s records (300, 300A, 301) plus the previous five (5) years of records. • Make sure records are readily accessible and that more than one person has access to the records. • Records do not have to be sent to OSHA unless OSHA requests. • Present employees, past employees and their representatives are allowed to view the Form 300 “Log”. • Forms can be kept on the computer as long as they can be produced when needed.

26. Employee was present in the work environment as a member of the general public and not as an employee. Injury/illness signs or symptoms appear at work but resulted solely from outside work. Incident occurred from voluntary participation in wellness program, fitness, medical, or recreational activities. Eating, drinking, or food prep for personal consumption even if bought on employer’s premises or brought in. Occurs solely from employee doing personal tasks at the establishment or outside working hours. Incident occurred from result of personal grooming, self-medication. There is a MVA which occurs in company parking lot or access road when employee is commuting. Common cold or flu. Mental illness (unless HCP states is work-related). Common SituationsNOT Recordable

27. How About Travel? • Is considered work-related if: • An injury or illness occurs while an employee is on travel status, or if it occurs while the employee was engaged in work activities. • If an employee detours for personal reasons than the incident is not work-related.

28. How About Working at Home? • Injuries & illnesses that occur while an employee is working at home are work-related if: • They occur while the employee is performing work for pay or compensation in the home and • Are directly related to the performance of work rather than the general home environment.

29. Other Required Reporting You must report any of the following to OSHA within 8 hours: • Fatality of any employee due to work-related incident. • Any in-patient hospitalization of 3 or more employees. • Report by phone or in person to an Area Office of OSHA or USDOL. • Report any fatal heart attack that occurred in the work environment.

30. Other Required Reporting – Sharps Log • OSHA 1910.1030(h)(5)(i) requires employers to maintain a sharps injury log for percutaneous injuries from contaminated sharps. • The log must: • Protect the confidentiality of the injured employee • Identify the type and brand of the device involved • Identify the department or work area where the incident occurred • Provide an explanation how the incident occurred • Be maintained like the 300 log (have the current log plus previous 5 years’ logs). • Enter the case on the OSHA 300 log as an injury but with no employee name (use “privacy case”).

31. References • OSHA 1910.1904 standard. • www.OSHA.gov