osha recordkeeping - eastern kentucky · pdf fileosha recordkeeping purpose: ... results from...
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OSHA Recordkeeping
Purpose: to require employers to record
and report work related fatalities,
injuries, and illnesses.
Exemptions: employers with fewer than
10 employees for the entire year;
business establishments classified as
low hazard retail, service, finance,
insurance, or real estate.
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Low Hazard Exemptions
SIC codes specifically listed in Appendix
A of the Recording and Reporting
Section of 29 CFR 1904
Includes hardware stores, meat and fish
markets, candy stores, new and used
car stores, gasoline service stations,
barber-beauty shops, insurance
carriers, others listed.
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Recording Criteria
1. Work related
2. is a new case
3. meets one or more specifics of
general recording criteria
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Work Relatedness
If an event or exposure in the work
environment either caused or contributed to
the resulting condition or significantly
aggravated a pre-existing condition.
The work environment includes areas where
one or more employees are working or
present as a condition of their employment
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Not Work Related
If the employee was present in the work
environment as a member of the general
public
Surfaces at work but resulted from a non
work related event or exposure
Results from a voluntary participation in a
wellness program, blood donation, exercise
class, flu shot, or other recreational activity
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Not Work Related
The injury or illness is solely the result of an employee preparing food or drink or eating/drinking for personal consumption
Results from performing personal tasks outside of work hours
Self inflicted or a personal grooming activity
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Not Work Related
Motor vehicle accident while commuting
to or from work
Common cold or flu
Mental Illness
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New Case
Is a new case if;
1. The employee has not previously experienced a recorded injury or illnes of the same type, or same part of the body; or
2. The employee had recovered completely and the injury caused the symptoms to reappear.
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General recording Criteria
Results in;
1. Death;
2. Days away from work;
3. Restricted work or job transfer;
4. Medical Treatment beyond first aid;
5. Loss of consciousness
6. A significant injury or illness diagnosed by a
physician
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Death
Notify OSHA within 8 hours of
occurrence
* Even if you are unsure if it is work
related- example- heart attack
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Days Away/Restricted/Transfer
Days Away- do not count the day of the
injury. Count calendar days from date
of injury to include RDO’s. If the number
is not known enter an estimated number
and correct later
Cap the number of days at 180
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Restricted/Transfer
Restricted if you keep the employee from performing one or more routine job functions or from working the full day
Or if a physician recommends the above
Routine functions are those that the employee performs at least once a week.
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Beyond First Aid
If the case involved medical treatment it
must be recorded- Medical Treatment is
above first aid; but is not a visit to a
physician or OHCP solely for
observation, conduct of diagnostic
procedures such as x-rays, blood tests,
or prescribed meds for diagnostic
purposes
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First Aid
Using non-prescription meds at non-prescription levels
Tetanus shots- purely preventive in nature
Cleaning, flushing, soaking
Wound coverings such as band-aids, butterfly strips, gauze.
sutures and staples are considered Med Treatment/wound closing devices
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First Aid
Hot or Cold Therapy
Using non-rigid means of support (wraps)
Using temporary immobilizing devices
Eye patches
Drilling fingernails, draining blisters
Removing foreign objects from an eye with swabs, or irrigation
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First Aid
Removing splinters by simple means
Using finger guards
Using massages ( Pt or chiropractic
visits are medical treatment)
Drinking fluids for relief of heat stress
* Procedure determines recording criteria,
not the status of the treating party
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Types of Cases
Sharps injuries- do not enter employees
name- denote case as a “S” or sharps case
Privacy Case- employee requests privacy or
injury is to intimate part of the body- do not
enter name- denote as “P”
Exposure cases-denote as an “E”-must keep
for 30 years after retirement/or separation
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Recording Criteria Decision Tree
Did the employee experience an
injury or illness?
Is the injury
or illness a new case?
Is the injury or
illness work-related?
Does the injury or illness meet the general recording criteria
or the application to specific cases?
Update the previously
recorded injury or illness
entry if necessary.
NO
YES
YES
YES
YES
Record the
injury or illness
Do not record the
injury or illness
NO
NO
NO
1904.4
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Musculoskeletal Disorders
Applies the same recording criteria to
musculoskeletal disorders (MSDs) as to
all other injuries and illnesses
Employer retains flexibility to determine
whether an event or exposure in the
work environment caused or contributed
to the MSD
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Tuberculosis & Medical
Removal Includes separate provisions describing the recording criteria for cases involving the work-related transmission of tuberculosis
Requires employers to record cases of medical removal under OSHA standards
1904.11 & 1904.9
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Employee Involvement
Requires employers to establish a procedure
for employees to report injuries and illnesses
and tell their employees how to report
Employers are prohibited from discriminating
against employees who do report
Employee representatives will now have
access to those parts of the OSHA 301 form
relevant to workplace safety and health
1904.35 & 36
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Employee Privacy Prohibits employers from entering an individual’s name on Form 300 for certain types of injuries/illnesses
Provides employers the right not to describe the nature of sensitive injuries where the employee’s identity would be known
Gives employee representatives access only to the portion of Form 301 which contains no personal information
Requires employers to remove employees’ names before providing the data to persons not provided access rights under the rule
1904.29(b)
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Annual Summary
Requires the annual
summary to be
posted for three
months instead of
one
Requires certification
of the summary by a
company executive
1904.32