osha’s new recordkeeping standard gayle w. fratto manager, safety engineering branch
TRANSCRIPT
OSHA’s New Recordkeeping Standard
Gayle W. Fratto
Manager, Safety Engineering Branch
Why is OSHA Recordkeeping Important??
Provides information to employers & employees on injuries/illnesses & related hazards in their workplaces
Employers: Management tool for administration of company safety & health programs
Employees: Raises awareness level
Provides OSHA compliance staff with information to facilitate inspections
Produces statistical data, thereby measuring magnitude of nation's injury & illness problem
OSHA VS. WRKR. COMP.
OSHA RECORDKEEPING REQUIREMEENTS ARE NOT THE SAME AS WORKER’S COMPENSATION REQUIREMENTS!!!!
New Forms
300 Log
301 Supplemental Form
300A Summary
Recording Criteria
Injuries and IllnessesWork Related
New Case
Meet one or more of Gen. Requirements
Additional Criteria
Additional Recording Criteria
Needlestick and Sharp
Tuberculosis
Hearing Loss
Medical Removal
MSD Cases
Exceptions to Work EnvironmentEE member of the general publicSymptoms at work but source isn’tResults voluntarily from wellness/recreation programsEating/Preparing foodsPerforming personal tasks outside of normal work hoursPersonal grooming, self medication (for non work related illness), self inflicted.Motor vehicle accident in co. parking lotCommon cold/flu
Exceptions (continued)
Common cold/flu
Mental Illness
Travel Status
Hotel
Detours
General Recording Criteria
For Injuries and Illnesses Death
Loss of consciousness
Lost work day
Restricted work time/Job transfer
Medical treatment
Significant injury or illness diagnosed by physician or licensed health care professional
Lost Work Days
Count Calendar Days
Doctor/Licensed Health Care Provider’s Opinion
Counting Cap – 180 days
Restricted Work Days/Job Transfer
Count Calendar Days
Capp – 180 Days
Permanent Transfer
Medical Treatment - Exceptions
Visits to Medical Professional Solely for Medical Observation
First Aid – (ex. Butterfly Dressings)
Diagnostic Procedures Prescription Medication (ex. eyes drops)
First Aid
Enclosed list of First Aid Treatments
No other treatment!
Significant Diagnosed Injury or Illness
Diagnosed by Physician or Licensed Health Care Specialist
Cancer
Chronic Irreversible Disease
Fractured or Cracked Bone (ex. Broken Toe, Broken Rib)
Punctured Eardrum
Hearing Loss
STS of 10db or more at 2000, 3000, and 4000 htz.
Adjusted for Age
Retesting – STS not Recorded if New Test Performed Within 30 days (with negative results)
Recording
Within 7 Calendar Days
Centralized RecordsRecorded within 7 calendar days
Make copies available • Employees
• Former employees
• Government Reps.
• Employees Reps
Privacy Concern
“Privacy Case” – In Place of EE NameInjury or illness to intimate part of the body
Sexual assault
Mental illness
HIV, hepatitis, tuberculosis
Contaminated needlestick/sharps cut
Other illness – If employee voluntarily requests it
Privacy Concern (cont.)
No Other Cases Classified as Privacy Case
Additional – Allowed Discretion in Describing Injury
300A - Summary
Separate PageFebruary 1, through April 30Signed by Company Executive
Company Owner – If sole proprietorship Officer of CorporationHighest ranking company official at worksiteImmediate supervisor of the highest ranking company official at the establishment
300 Disclosure
Disclosed by the End of the Next Business Day
Employee or Former Employee
Authorized Rep.
Personal Rep. Designated by the employee or former employee in writing
Legal rep. of a deceased or mentally incapacitated employee or former employee
301 Disclosure
Within 7 Calendar DaysAuthorized employee rep.
Only supply section entitled “Tell Us About the Case”
Next Business DayPersonal rep.
Employee or former employee
Retain/Maintain
300, 301, 300A Must be Retained for 5 Years Minimum
300 Must be Maintained for the 5 Years
Other Reporting
Fatalities/Mass Hospitalization (3 or More Employees)
Reported orally (to the Area Office nearest the incident)
Must be reported within 8 hours
Central number – 1-800-321-0SHA
Other Reporting (cont.)
Exception (Fatality/Mass Hospitilization)Motor vehicle accident on public street or highway.
Public Transportation
More than 30 days past accident
Still needs to be recorded
Government Representatives
Required to Supply Copies of Records
Must Be Supplied Within 4 Business Hours
Reps. Include:Rep. of Secretary of Labor
Rep. of Secretary of Health and Human Services (including NIOSH) conducting and investigation
Rep. of State agency responsible for admin. of state plan