August 26, 2009

1

• Understand OSHA’s Reporting requirements

• Understanding OSHA’s Recording requirements.

• Improve your awareness of hazards

• Answer your questions

Goals for this Session

The Mission…

To assure safe and healthful working

conditions for working men and women,

by authorizing enforcement of the

standards developed under the Act

August 26, 2009

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OSHA must prove

• Exposed employee

• Serious hazard

• Employer knowledge

• Feasible method to abate hazard

So how good is your safety and

health program?

• Management leadership– provide safety resources & organize effort

• Employee involvement

• Understanding of risk

• Hazard controls

• Training / Understanding

• Improvement annually

August 26, 2009

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Action items for an effective

safety and health program?

• Clear rules and expectations

• Employees understand the rules and expectations

• Process to discover deviations from expectations

• Effective enforcement program

Expanded reporting requirementsThe rule expands the list of severe work-related injuries and illnesses that all covered employersmust report to OSHA.

Starting January 1, employers must report to OSHA:

• All work-related fatalities within 8 hours (no change)

• All work-related in-patient hospitalizations of one or more employees within 24 hours

• All work-related amputations within 24 hours

• All work-related losses of an eye within 24 hours

www.osha.gov

August 26, 2009

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• By telephone to the nearest OSHA office during normal business hours.

• By telephone to the 24-hour OSHA hotline

– (1-800-321-OSHA or 1-800-321-6742).

• Online - available at: www.osha.gov/report_online.

www.osha.gov

How can employers report to OSHA?

What if the fatality or event occurs later?

If a fatality occurs within 30 days of the work-related incident, or if an in-patient hospitalization, amputation, or loss of an eye occurs within 24 hours of the work-related incident, then you must report the event to OSHA.

If the fatality occurs after more than 30 days of the work-related incident, or if the in-patient hospitalization, amputation, or loss of an eye occurs after more than 24 hours after the work-related incident, then you do not have to report the event to OSHA.

You must record these events on your OSHA injury and illness forms.

www.osha.gov

August 26, 2009

5

Heart attack - 1904.39(b)(5)

• Do I have to report a work-related fatality

or in-patient hospitalization caused by a

heart attack?

• Yes, your local OSHA Area Office director

will decide whether to investigate the

event, depending on the circumstances of

the heart attack.

Vehicle accident - 1904.39(b)(3)

• Do I have to report the fatality, inpatient hospitalization, amputation, or loss of an eye if it resulted from a motor vehicle accident on a public street or highway?

• If the motor vehicle accident occurred in a construction work zone, you must report the fatality, in-patient hospitalization, amputation, or loss of an eye.

• If the motor vehicle accident occurred on a public street or highway, but not in a construction work zone, you do not have to report the fatality, inpatient hospitalization, amputation, or loss of an eye to OSHA.

• However, the fatality, in-patient hospitalization, amputation, or loss of an eye must be recorded on your OSHA injury and illness records, if you are required to keep such records.

August 26, 2009

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Recordkeeping

• OSHA v Workers Compensation

• 5 years, 300, 300A, 301 or IL form 45

• Provided within 4 hours

August 26, 2009

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Forms - 1904.29

• Complete 300 & 301 within 7 calendar days

• May use equivalent form if it has the same information, readable, and understandable.

• Electronic forms

• Can be kept at another location as long as they can be produced when they are needed

OSHA 300A Form

August 26, 2009

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Company Exec.

Certification 1904.32

• Examined the log

• Based on their knowledge of the recordkeeping process, that the summary is accurate and complete

• Company executive– Owner

– Officer of the Corporation

– Highest ranking management official at facility

– Supervisor of highest ranking official on the site

Annual Summary1904.32

• Review OSHA Form 300 for completeness and accuracy, correct deficiencies

• Complete OSHA Form 300A - estimates

• Certify summary

• Post annual summary between February 1 and April 30

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Multiple Establishments1904.30

• Keep a separate 300 for each establishment

that is expected to be in operation for a year

• Each employee must be linked with an

establishment.

Covered Employees1904.31

• Employees on payroll

• Employees not on payroll who are supervised (specify output, product or result of the work or supervises the details, means, methods or processes) on a day-to-day basis

• Temporary agencies should not record the cases experienced by workers who are supervised by the using firm

August 26, 2009

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General Recording Criteria1904.7

• An injury or illness is recordable if it results in one or more of the following:

– Death

– Days away from work

– Restricted work activity

– Medical treatment beyond first aid

– Loss of consciousness

– Significant injury or illness diagnosed by a physician or other LHCP

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Nine Exceptions

1. Present as a member of the general public.

2. Symptoms arising in work environment that are solely due to non-work-related event or exposure.

3. Voluntary participation in wellness program, medical, fitness or recreational activity.

4. Eating, drinking or preparing food or drink for personal consumption.

Nine Exceptions

5. Personal tasks outside assigned working hours.

6. Personal grooming, self medication for non-work-related condition, or intentionally self-inflicted.

7. Motor vehicle accident in parking lot/access road during commute.

8. Common cold or flu.

9. Mental illness unless medical opinion

states work related.

August 26, 2009

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Medical treatment is the management and care of a patient to combat disease or disorder.

It does not include:

• Visits to licensed health care professional solely for observation

• Diagnostic procedures

• First Aid

Restricted Work / Job Transfer

1904.7(b)(4)

• Employee is kept from performing one

or more of the routine functions (at least

once a week) that he or she would

otherwise have been scheduled to

work.

• or

• An employee is kept from working a full

workday

August 26, 2009

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Day counts

• Day zero = day of injury or diagnosis

• Any day off work or restricted is a

day.

• Day of release does not count.

1904.8(a) Basic requirement

• You must record all work-related needlestick

injuries and cuts from sharp objects that are

contaminated with another person's blood or

other potentially infectious material

• You must enter the case on the OSHA 300 Log as an injury.

• To protect the employee's privacy, you may not enter the employee's name on the OSHA 300 Log

August 26, 2009

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Does this mean that I must record all cuts, lacerations, punctures, and scratches?

1904.8(b)(2)

• No, you need to record cuts, lacerations, punctures, and scratches only if they are work-related and involve contamination with another person's blood or other potentially infectious material.

• If the cut, laceration, or scratch involves a clean object, or a contaminant other than blood or other potentially infectious material, you need to record the case only if it meets one or more of the recording criteria in § 1904.7.

If I record an injury and the employee is later diagnosed with an infectious bloodborne disease,

do I need to update the OSHA 300 Log?

• Yes, you must update the classification of the case on the OSHA 300 Log if the case results in death, days away from work, restricted work, or job transfer.

• You must also update the description to identify the infectious disease and change the classification of the case from an injury to an illness.

August 26, 2009

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Practice recording

• The scrambler operator down at the fair was diagnosed with carpal tunnel syndrome from starting and stopping the scrambler. He was initially moved from his regular job to the milk can softball toss for 10 days.

• On the 12th day the employee had CTS surgery resulting in 50 days off of work.

• On day 62 the employee returned for a half day and then had 9 days of restricted activity.

• On day 73 employee has a complete recovery and a return to barking at the scrambler.

Work-related musculoskeletal disorders

(1904.12)

• Employers shall record these cases just as

they would record any other injury or illness.

• Check in column H (most serious)

• 50 (days) column K

• 20 (days)column L

• * Check in column M(6) *

August 26, 2009

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National Emphasis Program for Healthcare Facilities

– Ergonomic stressors - patient handling

– Exposure to blood and other potentially

infectious materials;

– Workplace violence;

– Slips, trips, and falls

What do we find?

• Bloodborne pathogens

• Electrical hazards

• Hazard communication

• Confined space

• Respiratory protection

• Reporting – not timely

• Personal protective equipment

• Recordkeeping

• Formaldehyde

• Lockout

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Cleaning and Laundering

• The employer shall clean, launder, and dispose of personal protective equipment required by the standard at no cost to employees.

• Contaminated laundry shall be placed and transported in labeled or color-coded bags.

August 26, 2009

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Labels

• Pictograms

• signal words

• hazard and

precautionary

statements

• the product

identifier

• supplier

identification.

Respiratory Protection

Program

• Program Administrator

• Written program – selection process

– Do you know the level of the contaminant?

• Medical evaluation

• Fit test

• Training

• Recordkeeping

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What else do we cite?

• Section 5(a)(1), General duty clause

– Ergonomic hazards

– Workplace Violence

– Biological Agents

– Hazardous Drugs

– Latex Allergy

– Occupational Asthma

– Ventilation

The general duty clause.

Section 5(a)(1)

Each employer shall furnish a

place of employment free of

recognizable hazards that are

likely to cause serious physical

harm.

August 26, 2009

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Injuries are caused by:

– Force

• Lifting own body weight plus

patient’s weight

– Awkward posture

• Twisting & Bending

Violence Prevention Plan

• Clear policy that violence, verbal and nonverbal threats, and related actions, will not be tolerated.

• No reprisals are taken against employees who report or experience workplace violence.

• Maintain security which includes law enforcement officials or specialists.

August 26, 2009

21

Please manage safety

Brian BothastLead Safety & Occupational Health Specialist

US DOL-OSHA

Peoria, IL

T: 309.589.7033

F: 309.589.7326

oshapeoria@dol.gov

www.osha.gov