Recordkeeping & Reporting Joe Margetiak Compliance Officer Toledo Area Office June 2015

Recordkeeping &Reporting

Joe MargetiakCompliance OfficerToledo Area Office

June 2015

RecordkeepingHighlights

Changes to 29 CFR 1904

Effective January 1, 2015

NAICS vs. SIC Codes

• Need to use NAICS from now on– North American Industry Classification System

(NAICS)– Standard Industry Classification (SIC)

• On-line guide available www.OSHA.gov• OSHA 300A forms need NAICS code

Partially Exempt from Recordkeeping

Do not have to keep OSHA 300 and OSHA 300A forms• Employers who have 10 or fewer employees at

all times during the previous calendar year• List of industries with injury rate 75% or less of

3-year average

Industry Examples

• Florists• Shoe Store• Sporting Goods Stores• Colleges• Restaurants• Car Dealers• Doctors

Injury ReportingRequirements

Changes to 29 CFR 1904

Effective January 1, 2015Published September 18, 2014

(proposed rule published June 22, 2011)

Previous Reporting Requirements

• Work-related fatality• Heart attack fatality• Hospitalization of 3 or more employees• Injuries involving a mechanical power press

– 1910.217(g)(1): The employer shall report, within 30 days of the occurrence, all point-of-operation injuries to operators or other employees

Notification requirementsas of January 1, 2015

• Work-related fatality • Work-related in-patient hospitalization • Heart Attack• Work-related amputation• Work-related injury resulting in the loss of an

eye• Mechanical power press point-of-operation

injury

Fatality

• Report within 8 hours of when you find out• If the fatality occurs within 30 days of the

work-related incident• Does not include traffic accidents (except

construction zones) & public transportation• Includes heart attack

Hospitalization

• Report within 24 hours• One or more employees• Admitted for treatment• If hospitalization occurs with 24 hours of incident• Includes heart attack• Observation or testing does not count• Does not include traffic accidents (except

construction zones) & public transportation

Heart Attack

• Heart attack vs. sudden cardiac arrest• Not always instantaneous – symptoms may occur

over a period of time*• May be caused by some work activity that

occurred hours earlier*• Sudden cardiac arrest, such as from an electrical

shock, may appear to be a heart attack*• May or may not be investigated by OSHA• Evaluated on a case-by-case basis

• * Mayo Clinic: Disease and Conditions Heart Attack• http://www.mayoclinic.org/diseases-conditions/heart-attack/basics/symptoms/CON-20019520

Amputation*

• Report within 24 hours• Does not include traffic accidents (except

construction zones) & public transportation• If amputation occurs with 24 hours of incident• Definition of amputation does not include: – avulsion, enucleations (loss of eye), deglovings,

scalpings, severed ears, broken/chipped teeth* as defined in BLS OIIC 2010 manual

Loss of an eye

• Report within 24 hours• If loss occurs with 24 hours of incident• Does not include traffic accidents (except

construction zones) & public transportation(no reference to blindness)

Reporting

• Can not leave a message on an OSHA answering machine/voice mail; no email; no fax

• Options:– Electronic reporting (not yet)

www.osha.gov/report_online

– Call OSHA hotline 800-321-6742– Call local office 419-259-7542 (8:00 - 4:30)