OSHA Injury & Illness Recordkeeping - KellerOnline€¦ · OSHA Injury & Illness Recordkeeping: Will your records stand inspection? ... Recordkeeping forms Forms: OSHA 300 Log 301

OSHA Injury & Illness Recordkeeping

Will your records stand inspection?

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Presented by KellerOnline®

KellerOnline® provides several resources on today’s topic:

– Topic Index (LOIs, ez Explanations, FAQs)• Recordkeeping (Injury & Illness)• National Emphasis Program (NEP)

– Incidents (Form 300/301) Recordkeeping Tool• Incident Portal – Coming Soon!

– Workers’ Compensation Recordkeeping Tool– Safety Training Programs– Safety Plans– Interactive Forms

© 2010 J. J. Keller & Associates, Inc.® 1

KellerOnline® Webcast – January 26, 2010 OSHA Injury & Illness Recordkeeping: Will your records stand inspection?

Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.

National Emphasis Program

• Low DART rates in high rate industries• Lack of record completeness• 40 or more employees• DART rate of 4.2 or less


What is the NEP?

Three objectives:• Ensure employers are recording injuries and

illnesses• Determine accuracy of injury and illness rate data• Determine what role occupational physicians play in

reporting data


H1N1 Influenza

Common cold and flu is not recordableH1N1 Influenza A virus is recordable if:

Confirmed as 2009 H1N1Work-relatedMeets recording criteria

Employer’s responsibility to determine



Musculoskeletal Disorders

Currently no WMSD recording requirementCurrently no 300 Log column for WMSDLast year, OSHA developed a proposed rule to add:

Definition for WMSDsAn WMSD column on the 300 Log

Help track WMSD injuriesProvide improved statistics on WMSD


Occupational injuries and illnesses

Lots of ‘gray’ recordkeeping areas• Work-related• Medical treatment• OTC meds• Parking lots• Breaks• Temps• Travel • Counting days• Exemptions


Recordkeeping forms

Forms:OSHA 300 Log301 Incident Report300A Summary

*These forms can be found in KOL in the Topic Index > Recordkeeping.



Partial exemptions for:

Company size: 10 or fewer employeesLow hazard industry: 75% below the national average

Who’s covered by the rule


ALL employers must report

Work-related fatalitiesHospitalization of 3 or more workersCall the hotline 800-321-OSHA


Who is a covered employee?

All employees on your payroll:

Salaried/Hourly Labor/ExecutiveSeasonal/Migrant Full-time/Part-timeTemporary/Leased



Daily supervision

Each case is recorded only once

If you supervise:Your 300 LogIf the leasing agencysupervises:Agency’s 300 Log


Poll question

Does the fact that an employee reports that he or she was injured in the workplace mean you have to record it?

YesNo


Poll question

“The mere reporting . . . does not make itrecordable . . .”

Employer must determineif an injury or illness hasoccurred



1. Work-related

In the work environmentcaused or contributed to the conditionpresumed for injuriesand illnessesdiscernable cause orsignificant aggravationneed not be the soleor predominant cause


2. New case

No previous injury to the body part

OR

Completely recoveredFrom the injury


3. Recording criteria

General recording criteriaDeathDays awayRestrictionTransferMedical treatmentLoss of consciousnessSignificant injury or illness



3. Recording criteria

Specific recording criteriaContaminated sharpsHearing lossTuberculosisMedical removal


General recording criteria

1. DeathReported within 8 hoursHeart attacks

2. Days away from workHealthcare professionalEmployer


3. Loss of consciousness

4. Diagnosis of a significant injury/illness





5. Restricted workOne or more routine job functions, orKeeps employee from working a full day.

6. Job transfer“….assigning to

another job forpart of the dayor a full day….”



7. Medical treatment beyond first aidFirst aid treatments listed at 1904.7(b)(5)(ii)


Poll question

Are insect bites and stings recordable?YesNoOnly if it meets the criteria



Poll question

If the case meets the recording criteria, it’s recordable

Most bites and stingswon’t be recordable

Recordable even ifemployee “self-injects”


What is first aid?

Nonprescription medication at nonprescription strengthTetanus shotsCleaning, flushing or soaking wounds on the surface of the skinWound coveringsHot or cold therapyNon-rigid means of supportTemporary immobilization devices


What is first aid?

Drilling a fingernail or toenail, or draining a blisterEye patchesRemoving foreign bodies from the eye using only irrigation or a cotton swabRemoving splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple meansFinger guardsMassagesDrinking fluids for relief of heat stress



Wound coverings vs. closings

Not recordable:Band-aidsButterfly bandagesSteri-stripsLiquid bandages

Recordable:SuturesStaplesSurgical glues


Medical treatments

Not recordable:Diagnostic proceduresCounselingMassage

Recordable:ManipulationWork restrictions


Contemporaneous opinion

. . . Occurring at the same time . . . “More authoritative”Treatment has not occurredExamination in sametime frameNo prescription waswritten



Non-prescription drugs given at prescription strength

Single doses of common OTC drugs taken at prescription strength are recordable


Non-prescription drugs given at prescription strength

Ibuprofen < 467 mgDiphenhydramine < 50 mgNaproxen Sodium < 220 mgKetoprofen < 25 mg


Prescription-strength medications

Recordable:Sample prescription medsOTCs at prescription strengthPrescriptions given but not filledPreventative medicines



Bloodborne pathogens

Needlestick and sharps injuries are recordable if contaminated with:

1.Blood2.Body fluids


Bloodborne pathogens

Must update the 300 Log if it results in:DeathDays away from workRestricted workJob transfer


Hearing loss

Standard threshold shift (STS)

Audiometric zero

Work-related



Hearing loss example

40353025

30 annual

201510

50 audiometric

20 baseline 20 annual

10 baseline

Recordable Not recordable


Medical removal

It is recordable if:Removal required by other OSHA standards

It is NOT recordable if:Voluntarily before medical removal levels occur


Oxygen

It is recordable if:Given to relieve symptoms

It is NOT recordable if:Given as a precaution



Travel status

Injuries or illnesses occurring to employees on “travel status” are work-related the employee was engaged in work activities in the interest of the employerIt is not recordable if the employee was:

In a “home away from home”Taking a detour for personal reasons


Loss of consciousness

It is recordable if:Complete loss of consciousnessRegardless of timeApplies to mandatory medical procedures

It is NOT recordable if:Results from personal medical conditionOnly become light-headed

Must be work-related.


How to count

Do NOT count thefirst dayPartial days ofwork areconsidered to berestricted daysMust record within7 days



How to count

Count calendar daysNOT

work daysNo partial daysCap count at 180days


How to count

Record each case only onceLog all days in the year the injury occursEstimate days if needed for theSummary


Recording exceptions

1. Employee present as member of general public

2. Symptoms which surface at work




3. Voluntaryparticipation in wellness programs or recreational activity



4. Eating, drinking, or preparing food brought from home or purchased in the workplace



5. The injury or illness resulted from:Personal tasks are unrelated to employment, andThe activity wasperformed outsideof assigned workhours




6. Injuries that are solely the result of:Personal groomingSelf-medication for non-work conditionIntentionally self-inflicted


Poll question

An employee falls down, breaks his arm, and fails a post-accident drug test. Can you stop the day count when you terminate?

YesNoIt depends


Poll question

OSHA allows you to stop your count . . .for reasons unrelated to the injury.

The drug test isrelated to the injury




7. Vehicle accidents in company parking lots or access roads during a commute

Employer controlPublic parking lots



8. Common cold and fluvs. Other infectiousdiseases

9. Mental illness


300A Summary

Post between February 1st and April 30thMust be certified by a “company executive”A “company executive” is:

An owner;An officer of the corporation;The highest ranking official at the establishment; orThe immediate supervisor of the highest ranking company official working at the establishment.



To review

To be recordable:work-relatednew casemeet recording criteria

List of first aid treatments is comprehensive –anything not on the list is medical treatment

Post 300A from Feb. 1st through April 30th


Recordkeeping in KellerOnline

Incident Portal

Coming Soon!


Recordkeeping in KellerOnline

Incident Portal

Coming Soon!



Questions?

If you have questions, please use the Q&A function in the upper right of your screen. If we don’t get to your question today, please use

the Personal Assistant feature (shown below).

Thank you for participating!

Bloodborne Pathogens Standard will be presented on

Wednesday, February 24th @ 1PM Central Time


Documents

OSHA Injury & Illness Recordkeeping - KellerOnline€¦ · OSHA Injury & Illness Recordkeeping: Will your records stand inspection? ... Recordkeeping forms Forms: OSHA 300 Log 301