OSHA Recordkeeping

CONN-OSHA Breakfast Roundtable Discussion

Group

January 20, 2015

2

Purpose of Recordkeeping

• To require employers to record and report work-related fatalities, injuries and illnesses

• OSHA injury and illness recordkeeping and Workers’ Compensation are independent of each other

• Does not mean• The employer or employee was at fault• An OSHA rule has been violated,• The employee is eligible for workers’

compensationRemember, OSHA rules and regulations are made with the worst employers in mind.

1904.1 Small employer (10 or less)

1904.2 Industry Now listed by NAICS (North American Industry Classification

System)

1904.3 Other Federal agencies

Partial Exemptions for Private Sector

Effective January 2015, the list of exempt industries has changed.

OSHA Records: Government

Upon request, you have 4 business hours to provide government representatives copies of

– OSHA 300 Log– OSHA 300A Summary– OSHA 301 Incident Report– Confidential listing of privacy

concern cases, including names of the employees

Requirements for ALL Employers

1904.39 Report fatalities with 8 hoursWithin 24 hours report:

• amputations• the loss of an eye• in-patient hospitalization of an employee

1904.41-Annual OSHA injury and illness survey (if selected by OSHA)

1904.42-BLS Annual Survey of Occupational Injuries and Illnesses (if selected by BLS)

OSHA Records: Employee Access

• Post the OSHA Summary Form 300A at worksite from February 1st through April 30th.

• Upon employee request, you have until the end of the next business day to provide:– Copies of OSHA Forms 300 Log & 300A

Summary– His or her individual OSHA Form 301

• Includes requests from former employees and personal or authorized representatives

First Aid Defined, 1 of 3

• Visits to a PLHCP* solely for observation or counseling.

• Diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications solely for diagnostic purposes (e.g., eye drops to dilate pupils).

• Using non-prescription medications at non-prescription strength (per box instructions).

• Administering tetanus immunizations.• Cleaning, flushing or soaking wounds on

the surface of the skin.* Physician or other Licensed Health Care Professional

First Aid Defined, 2 of 3

• Using wound coverings such as bandages, Band-Aids, gauze pads, butterfly bandages, Steri-Strips, and other similar coverings.

• Using any non-rigid means of support such as elastic bandages, wraps, non-rigid back belts, etc.

• Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.).

• Drilling of fingernail or toenail to relieve pressure, or draining fluid from a blister.

First Aid Defined, 3 of 3

• Removing splinters or foreign material from areas other than the eyes by irrigation, tweezers, cotton swabs or other simple means.

• Removing foreign bodies from the eye using only irrigation or a cotton swab.

• Using eye patches or finger guards.• Non-therapeutic massages (spa

treatment).• Using hot or cold therapy.• Drinking fluids for relief of heat

disorder.

Column H: Days Away from Work

• An injury or illness involving one or more days away from work.

• Do not include the day of the injury or onset of illness.

• A job restriction/transfer is recommended, but if the employer cannot accommodate this, the employee stays home.

Column I: Job Transfer or Restriction

• Record cases with days of job transfer or restriction but absolutely no days away from work.

• Do not include the day of injury or onset of illness.

• If a restriction or transfer is recommended, but such work is not available and the employee stays home, the case is counted in Column H: Days Away from Work.

Cases with Days Away AND Job Transfer or Restriction

• Record the case ONCE AND ONLY ONCE in Column H. Leave Column I blank.

• This is true even if the number of job transfer/restriction days is greater than the number of days away from work.

• Record the number of days away in Column K and the number of transfer/restriction days in Column L.

Example: Rob is out of work for 2 days and on restricted duty for 10 days.

X 2 10

• If a case is limited to First Aid treatment and there is no lost time - days away from work or job transfer/restriction – it is not recordable.

• This is true even if the First Aid treatment is administered at a health clinic, emergency room, hospital, or other medical treatment facility.

Remember…

Are these cases recordable?

• Susan falls in the parking lot. Her right leg is heavily bruised and she stays at home the next day to recover. No medical treatment.

• Carl trips at work, hurting his ankle. He goes to the emergency room for an X-ray, which shows the ankle is not broken, and returns to work the next day.

• Peter cuts his finger at work, receives stitches at the walk-in clinic, and immediately returns to work.

Yes

No

Yes

Column M: Injury and Illness Type

• For every recordable case, there must be a check mark in an injury or illness category.

• The total number of cases (G+H+I+J) MUST equal the total for Column M (1+2+3+4+5+6).

OSHA 300A Summary

0 3 1 2

10 2

4

1 1

Total of 6 casesTotal of 6 cases

Total of 6 injuries and illnesses

=

Employment & Hours

Total Hours ÷ Average # Employees ÷ 50 weeks =Average number of hours worked per week per employee.

OSHA 300A SummaryHair Club for Men

516 Blueberry Lane

Manchester CT 06040

Hair Replacement Services

7299

812199

80

160,000

President & Client

01/20/2014

Sy Sperling860 555-2343

160,000 ÷ 80 ÷ 50 = 40 hours per week per person

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

• Record splashes or other exposures to blood or other potentially infectious material if it results in a diagnosis of a bloodborne disease or meets the general recording criteria

DART Rate

• Days Away, Restricted, or Transferred

• Indicates how many days away, restriction, or transfer cases occur per 100 full-time workers.

• Calculated using the information on the OSHA Form 300A

• Used by Federal OSHA to identify companies with DART rates above the national average.

DART Rate Formula

(Columns H + I) x 200,000

Total Hours Worked

U.S. DART Rate 1.8 (Days away, Restricted, or Transferred cases per 100 full-time workers)

Private 1.7Public 2.3CT DART Rate 2.3Private 2.1Public 3.5

TRC Rate

• Total Recordable Cases• Indicates how many non-fatal

recordable cases occur per 100 full-time workers.

• Calculated using the information on the OSHA Form 300A.

TRC Rate Formula

(Columns H+I+J) x 200,000

Total Hours Worked

U.S. TRC Rate 3.5 (Recordable cases per 100 full-time workers)

Private 1.8Public 5.2CT TRC Rate 4.1Private 2.1Public 6.9

Resources• U.S. OSHA www.osha.gov

• Incidence Rate Calculator and Comparison Tool http://data.bls.gov/IIRC/calculate.do

• North American Industry Classification System www.naics.org

• Connecticut Department of Labor www.ct.gov/dol

• Workers’ Comp First Report of Injury form http://wcc.state.ct.us/download/acrobat/fri.pdf

• Joanne Regan – OSHA, Regan.Joanne@dol.gov, 617-565-9856

OSHA Recordkeeping

Questions???