OSHA RecordkeepingWhat You Need to Know

Presented By: Daecher Consulting Group, Inc.

Index• Workers’ Compensation Documentation• Labeling and Filing System• Workers’ Compensation Recordkeeping• OSHA 300 Log Documentation• Case Study & OSHA Recording• OSHA 300A Summary Documentation• Maintaining OSHA Records

Workers’ Compensation Documentation

Standard Documentation• OSHA 301: Incident Report or Equivalent• First Report of Injury• Correspondence to & from Insurance Carrier• Doctors Notes including Release to Full Duty• Additional Comments for Case

Additional Documentation• Copy of Disciplinary Actions Taken• Copy of Receipt of Remedial Training• Copy of Post Accident Drug & Alcohol Testing

Labeling & Filing System• Each case should be filed separately, no matter if it is an

employee with multiple cases, each case should be filed separately.

• Develop a labeling system for folder: Assign a specific case number to each individual incident, so that each case can be easily differentiated. [Examples below: FA(D.O.I.), M(D.O.I.) & R(#)]

First Aid Medical(Non-Recordable)

OSHA Recordable

Recordkeeping System

Recordkeeping System

OSHA RecordkeepingOSHA Forms• OSHA 301: Injury and Illness Incident Report• OSHA 300 Log• OSHA 300A Summary

Implementation• Determine if the case is work related and if so, does the

case meet the OSHA recording criteria.• You must enter each recordable injury or illness on the

OSHA 300 Log and 301 Incident Report (or equivalent) within seven (7) calendar days of receiving information that a recordable injury or illness has occurred.

OSHA RecordkeepingWork-Related: An injury or illness is considered work-related if an event or exposure in the work environment caused or contributed to the condition or significantly aggravated a preexisting condition. Work-relatedness is presumed for injuries or illnesses resulting from events or exposures occurring in the workplace unless an exception applies. See 29 CFR 1904.5(b) Implementation “Determination of work-relatedness”.

A work-related injury or illness must be recorded if it results in one or more of the following:

A. DeathB. Days away from workC. Restricted work or transfer to another jobD. Medical Treatment beyond first aidE. A significant injury or illness diagnosed by a

physician or other licensed health care professional

OSHA RecordkeepingAlong with recording work-related fatalities on the OSHA Logs there is also a requirement to report fatalities to the government.

– Employers must orally report work-related fatalities and multiple hospitalization incidents to OSHA within eight (8) hours after the death of any employee from a work-related incident or the in-patient hospitalization of three (3) or more employees.

– These incidents should be communicated by telephone or in person to the Area Office of the Occupational Safety and Health Administration (OSHA), U.S. Department of Labor, that is nearest to the site of the incident.

– Toll free OSHA central telephone number 1-800-321-OSHA

OSHA RecordkeepingDo I have to report every fatality or multiple hospitalization incident resulting from a motor vehicle accident?

– No, you do not have to report all of these incidents. If a motor vehicle accident occurs on a public street or highway, and does not occur in a construction zone, you do not have to report the incident to OSHA.

Do I have to report a fatality or multiple hospitalization incident that occurs in a commercial or public transportation system?

– No, you do not have to call OSHA to report a fatality or multiple hospitalization incident if it involves a commercial motor vehicle, airplane, train, or subway accident.

OSHA RecordkeepingMedical Treatment Beyond First AidMedical Treatment – means the management and care of a patient to combat disease or disorder. For purposes of Part 1904, medical treatment does not include:

– Visits to the physician or other licensed health care professional solely for observation or counseling

– The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes

– Any procedure that can be labeled first aid

OSHA RecordkeepingFor the purposes of Part 1904, first aid means the following:

– Using non-prescription medication at non-prescription strength

– Administering tetanus immunizations– Cleaning, flushing, or soaking wounds on the surface

of the skin– Using wound coverings– Using hot or cold therapy– Using any non-rigid means of support– Using temporary immobilization devices while

transporting an accident victim

OSHA RecordkeepingFirst Aid Continued…

– Drilling of fingernail or toenail to relieve pressure or drain fluid from a blister

– Using eye patches– Removing foreign bodies from the eye using only

irritation or a cotton swab– Removing splinters or foreign materials from areas

other than the eye– Using finger guards– Using massages (physical therapy or chiropractic

treatment are considered medical treatment)– Drinking fluids to relieve heat stress

OSHA RecordkeepingRecording Loss of Consciousness• You must record a work-related injury or illness, on the

OSHA 300 Log, if a worker becomes unconscious, regardless of the length of time the employee remains unconscious.

Recording a Significant injury or illness• Work-related cases involving cancer, chronic irreversible

disease, a fractured or cracked bone, or a punctured eardrum must always be recorded under the general criteria at the time of diagnosis by a physician or other licensed health care professional.

OSHA RecordkeepingHow to work with the OSHA 300 Log1. Identify the employee involved unless there is a privacy

concern. (HIV infection, hepatitis, tuberculosis, etc.)2. Identify when and where the case occurred3. Describe the case, as specifically as you can4. Classify the seriousness of the case by recording the

most serious outcome associated with the case; (Column J [other recordable case] being the least serious and column G [Death] being the most serious)

5. Identify whether the case is an injury or illness by checking the appropriate column

OSHA RecordkeepingCounting Days• Count the number of calendar days the employee was

on restricted work activity or was away from work as a result of a recordable injury.

• Do not count the day on which the injury or illness occurred in this number, begin counting days from the day after the incident occurred.

• Week days, weekend days, holidays, vacation days, or other days off are included in the total number of days recorded until the day that the employee returns to full duty. Do not include the day the employee returns to full duty in the total number.

• You may stop counting days of restricted work activity or days away from work once the total of either or a combination of both reaches 180 days.

OSHA RecordkeepingScenario #1• A mechanic named Mike Doe cut his forearm on the bench grinder.

As a result, Mr. Doe went to visit the doctor and the results are as follows:– Date of injury – Tuesday November 3rd– Patient received stitches on his forearm– Patient may return to full duty without restrictions

• Calendar dates are as follows:

• Complete the OSHA 300 Log entry

OSHA Recordkeeping

OSHA RecordkeepingScenario #2• A mechanic named Steve Doe strained his back while trying to lift a

tire off of the tire changer in the tire maintenance area. As a result, Mr. Doe went to visit the doctor and the results are as follows:

– Date of injury – Thursday November 5th– Patient may return to work with restrictions– Patient may return to full duty without restrictions on Monday November

16th

• Calendar dates are as follows:

• Complete the OSHA 300 Log entry

OSHA Recordkeeping

OSHA RecordkeepingScenario #3• A mechanic named John Doe sprained his ankle while exiting the Bay 3

service pit. As a result, Mr. Doe went to visit the doctor and the results are as follows:– Date of injury – Friday November 6th– Off work; May not return to work– May return to work with restrictions on Wednesday November 11th – May return to full duty without restrictions on Tuesday November 24th

• Calendar dates are as follows:

• Complete the OSHA 300 Log entry

OSHA Recordkeeping

OSHA RecordkeepingScenario #4• A mechanic named Joe Schmoe fell down the stairs to the overhead

storage area and sprained his wrist. As a result, Mr. Schmoe went to visit the doctor and the results are as follows:– Date of injury – Tuesday November 17th– Patient was given an X-ray, an ice pack and regular strength non-

prescription Tylenol– Patient may return to full duty without restrictions

• Calendar dates are as follows:

• Complete the OSHA 300 Log entry

OSHA RecordkeepingScenario #4 does not meet the OSHA Recording Criteria and does not need to be recorded on the OSHA 300 Log. The treatment that was given is classified as First Aid.

OSHA RecordkeepingWhat if the outcome changes after you record the case?If the outcome or extent of an injury or illness changes after you have recorded the case, simply draw a line through the original entry or, if you wish, delete or white-out the entry. Then write the new entry where it belongs. Remember, you need to record the most serious outcome for each case.

What if an injury or illness carries over to the next year?If an injury or illness carries over to the next year, a new case is not logged onto the following years OSHA logs. All information for an injury or illness should be recorded on the OSHA log during which the injury or illness occurred.

OSHA RecordkeepingHow to work with the OSHA 300A Summary1. Enter Establishment Information 2. Describe Industrial Classification and List SIC (Standard

Industrial Classification) Code3. Enter Employment Information4. Add up columns [G thru L] & [1 thru 5] and list the totals

at the bottom of each column on the OSHA 300 Log5. Transfer column totals from the OSHA 300 Log to the

corresponding columns on the OSHA 300A Summary6. You must post a copy of the summary at the

establishment, in a conspicuous place, between February 1 and April 30 the year following the year covered by the records.

OSHA Recordkeeping

OSHA Recordkeeping

OSHA RecordkeepingMaintaining OSHA Records• You must save the OSHA 300 Log, the annual summary,

and the OSHA 301 Incident Report forms for five (5) years following the end of the calendar year that these records cover.– You must update the stored OSHA 300 Log to include

the newly discovered recordable injuries or illnesses and to show any changes that have occurred in the classification of previously recorded injuries and illnesses.

– You do not have to update the annual summary or the OSHA 301 Incident Reports, but you may wish to do so.

Conclusion

Questions and Answers

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