your compliance manual to osha's 300 and 300a forms
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YOUR COMPLIANCE MANUAL TO OSHA’S
300 AND 300A FORMSThe painless path to compliance by the
Feb. 1st deadline.
December 15, 2016
2
Who’s on the Line
KYLE MEINERT, ASPHNI Risk Advisor
kmeinert@hni.com
To Our Sponsors: Thank You!
Objectives of Training
• OSHA UPDATES!• Do I record or do I not record?• Which forms do I use?
• How to fill them out• Where to put them after completion
• What’s considered an OSHA recordable?• What’s considered first aid?• Filing requirements
OSHA UPDATES!
“Improved” Tracking of Workplace Injuries and Illnesses• Data will also be posted to the
OSHA website and made public. • Employee count is based on
location• Anticipate striking the “or
equivalent form”oWC forms may not be
acceptable for 301’s All submissions must be done electronically!
Drug Testing: OSHA Stance
“The rule does not prohibit drug testing of employees. It only prohibits employers from using drug testing, or the threat of drug testing, as a form of retaliation against employees who report
injuries or illnesses..”
OSHA Reporting Updates
OSHA Area Office P.O.C.Contact the office nearest the incident.
• Appleton Area Office1648 Tri Park WayAppleton, Wisconsin 54914(920) 734-4521(920) 734-2661 FAX
• Eau Claire Area Office1310 W. Clairemont AvenueEau Claire, Wisconsin 54701(715) 832-9019(715) 832-1147 FAX
• Madison Area Office4802 E. BroadwayMadison, Wisconsin 53716(608) 441-5388(608) 441-5400 FAX
• Milwaukee Area Office310 West Wisconsin Avenue, Room 1180Milwaukee, Wisconsin 53203(414) 297-3315(414) 297-4299 FAX
https://www.osha.gov/html/RAmap.html
OSHA Must Be Notified…. What’s Next?
• Rapid response investigations (RRI)
oQuestions OSHA WILL ask
oOSHA’s triaging once reported• Root cause analysis with documented evidence
• What may trigger an inspection?
OSHA 300, 301, 300A
How do I Know If I Need to Record This Info?
• Many but not all employers.• Exceptions are based on:
• Small employer exemption – 10 or fewer employees at all times during the year*
• Low-hazard industry exemption based on North American Industrial Classification System (NAICS) code.o Retail onlyo Insurance firmso Banks o Etc.
What Forms Must Be Completed?
• 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
What Criteria Must be Met to be Consideredan OSHA Recordable Injury/Illness?• Injuries and illnesses• Work related• Meet certain severity criteria
What Exactly is an Injury or Illness?
• An abnormal condition or disorder• Fractures• Sprains • Respiratory conditions• Symptoms of…
• Not an exposure, unless it results in signs or symptoms
• Observations or diagnostics only…
Work Relatedness
• Cases caused by events or exposures in
the work environment
• Cases contributed to by events or
exposures in the work environment
• Cases significantly aggravated by events
or exposures in the work environmentWhat do you think: Work-related
injury in the works?
Any contribution to the injury!
What’s NOT Work Related?? 1904.5(b)(2)(i-vi)
• The incident happens at work but is the result solely
from a non-work-related event or exposure
• Voluntary participation in a wellness program
• Eating, drinking, or preparing food
• Mental Illness (unless a qualified person determines it
is work related)
• Establishes a “Home-Away-From-Home”
Work Related
Non-Work Related*
Other Considerations for By-Mile Employees
• Injuries experienced while driving a truck route or while
loading or unloading, is considered work related for
OSHA recordkeeping purposes
• Sleeper berth injuries are not considered work related
• Injuries in a motel or hotel are not considered work
related.
• Any injury or illness experienced while stopped for
eating/bathing are not considered work related.
Severity Requirement
• Death
• Loss of consciousness
• Days away from work
• Restricted work activity or job transfer
• Medical treatment beyond first aid*
• Prescription grade medication
What is Considered First Aid?
• Non-prescription medication at non-prescription strength
• Tetanus immunizations
• Cleaning, flushing, soaking superficial wounds
• Wound coverings
• Hot or cold therapy
• Non-rigid supports
• Temporary immobilization devices
• Drilling fingernails
• Eye patch
• Simple irrigation or use of cotton swab to remove foreign material from eye (not embedded)
• Splinters that can be removed with tweezers (exception: eye)
FAQs• When do I start counting days?
• Day 1 on the log = Day 2 of the injury
• What if an employee has been restricted but still elects to work anyway?• Always encourage employees to follow physician recommendations• If the employee insists, these days are still considered days away
• An employee is cleared to work but does not want to come back.• As-soon-as the physician states the employee can return to work the following days are no longer counted
as days away but may be restricted/transfer days
• An employee was hurt on Friday and returns to work the following Friday, how many days away is this?• Days are counted on a calendar basis, this would be 6 days away• If employee returns on Monday, and the physician indicated that the employee should not have worked the
weekend these days are also counted.
OSHA Injury and Illness Form
https://www.osha.gov/recordkeeping/RKform300pkg-fillable-enabled.pdf
The OSHA 300 Log
• Maintained all year…
• Injury no loss time• Injury loss time
oHow to calculate days
oType of injury• Restricted or
reserved • Digital 300 Logs
OSHA 300 Log: Days Away2015
OSHA 300: Restricted Work or Transfer2015
OSHA 300 Log: Days Away & Restricted2015
OSHA 300: Beyond First Aid2015
Days Away: For the Employees Paid by Mile
OSHA 300a: Deadline is Days Away
OSHA Form 301: Injury and Illness Report
How Long do I Need to Keep These?
Five years.
300 300a Wrap Up• What did we cover again??
oOSHA update
o Exceptions to the standard
o Forms Overview- 300
- 300a
- 301
oWhat’s considered an OSHA recordable event
oDetailed steps on completion of forms
Questions?
Please forward any remaining questions you have to Kyle Meinert [kmeinert@hni.com]
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