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OSHA Recordkeeping Training

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Title: OSHA Recordkeeping Training


1
OSHA Recordkeeping Training New Regulation
2
Course Outline
  • 1.0 Overview
  • 2.0 Recording Injuries Illnesses
  • 3.0 Maintenance Retention of Records
  • 4.0 Posting Requirements

3
1.0 Overview
  • Federal OSHA, under Clinton Administration, made
    changes to the requirements for recording work
    related injuries and illnesses.
  • California must adopt a regulation as effective
    by the end of December.

4
Records Consist of Three Forms
  • OSHA 300 Log of Occupational Injuries and
    Illnesses
  • OSHA 300A Annual Summary of Occupational
    Injuries and Illnesses
  • OSHA 301 The Supplementary Record of
    Occupational Injury and Illnesses. Equivalent to
    Form 5020, Employers Report of Occupational
    Injury or Illness

5
2.0 Recording Injuries Illnesses
  • Recordable Cases only
  • Recording an injury or illness under the OSHA
    System does not imply that an employer was at
    fault, that the worker was at fault, that a
    violation of an OSHA standard has occurred. Or
    that the injury or illness will be compensable
    under Workers Compensation. It is not an
    admission of liability.

6
Key Terms
  • Recordable Any work-related injury or illness in
    the work environment that is a new case and
    results in
  • Loss of consciousness
  • Restricted work activity or job transfer
  • Days away from work not counting the day of
    injury
  • Medical treatment beyond first aid
  • Fatality
  • Diagnosed occupational illness

7
Definition
  • Work Environment The establishment other
    locations where one or more employees are working
    or are present as a condition of their
    employment. The work environment includes not
    only physical locations, but also the equipment
    or materials used by an employee during the
    course of his/her work.

8
Clarification Work Environment is Not
  • If the employee was injured when in the work
    environment as a member of the general public
  • The injury/illness involves signs or symptoms
    that surface at work but result solely from a
    non-work-related event that occurs outside the
    work environment
  • The injury/illness results solely from voluntary
    participation in a wellness program or in a
    medical, fitness, or recreational activity

9
Clarification Work Environment is Not
  • The injury/illness is solely the result of an
    employee eating, drinking, or preparing food or
    drink for personal consumption.
  • The injury/illness is solely the result of an
    employee doing personal tasks at the
    establishment outside of the employees assigned
    working hours.
  • The injury/illness is solely the result of
    personal grooming, self-medication for a
    non-work-related condition or is intentionally
    self-inflicted.

10
Clarification Work Environment is Not
  • The injury/illness is caused by a motor vehicle
    accident occurs on a company parking lot or
    company access road while the employee is
    commuting to/from work.
  • The illness is the common cold or flu.
  • The illness is a mental illness unless a
    psychiatrist or psychologist has stated that the
    employee has a mental illness that is
    work-related.

11
Definition
  • New Case
  • The employee has not previously experienced a
    recorded injury/illness of the same type that
    affects the same body part, or
  • The employee previously experienced a recorded
    injury/illness of the same type that affected the
    same part of the body but had recovered
    completely from the previous injury/illness and
    an event or exposure in the work environment
    caused the signs or symptoms to reappear

12
New Case Clarification
  • For occupational illnesses where the signs or
    symptoms may recur or continue in the absence of
    an exposure, the case must only be recorded once.
  • The episode is a new case if the symptoms (e.g.,
    occupational asthma) are the result of an event
    or exposure

13
Definition
  • Medical Treatment The management care of a
    patient to combat disease or disorder.
  • Does not include
  • Visits to a physician solely for observation or
    counseling
  • Diagnostic procedures such as x-rays or blood
    tests, including the administration of
    prescription medications used solely for
    diagnostic purposes (e.g., eye drops to dilate
    pupils).
  • First Aid Treatment

14
Definition
  • First Aid
  • Using a nonprescription medication at
    nonprescription strength
  • Administering tetanus immunizations (other
    immunizations such as Hepatitis B vaccine are
    considered medical treatment)
  • Cleaning, flushing or soaking wounds on the
    surface of the skin
  • Using wound coverings such as bandages,
    Band-Aids, gauze pads, butterfly bandages, or
    Steri Strips (sutures, staples, etc are
    considered medical treatment)

15
Definition Continued
  • Using hot or cold therapy
  • Using any non-rigid means of support, such as
    elastic bandages, wraps, non-rigid back belts
    (devices with rigid stays are considered medical
    treatment)
  • Using temporary immobilization devices while
    transporting an accident victim
  • Drilling of a fingernail or toenail to relieve
    pressure, or draining fluid from a blister
  • Using eye patches

16
Definition Continued
  • Removing foreign bodies from the eye using only
    irrigation or a cotton swab
  • Removing splinters or foreign material from areas
    other than the eye by irrigation, tweezers,
    cotton swabs, etc.
  • Using finger guards
  • Using massages (physical therapy or chiropractic
    treatment are considered medical treatment)
  • Drinking fluids for relief of heat stress

17
Definition
  • Pre-existing Conditions An injury/illness is a
    pre-existing condition if it resulted solely from
    a non-work-related event or exposure that
    occurred outside the work environment

18
More Recordables
  • A pre-existing injury/illness should be recorded
    if it is significantly aggravated when an
    event/exposure in the work environment results in
    any of the following
  • Death, provided that the pre-existing
    injury/illness would likely not have resulted in
    death but for the occupational event or exposure
  • Loss of consciousness
  • One or more days away from work, or days of
    restricted work, or days of job transfer
  • Medical Treatment if not needed before the
    workplace event or exposure

19
Travel
  • Injuries or Illnesses that occur while an
    employee is on travel status are work-related if,
    at the time of the injury/illness, the employee
    was engaged in work activities in the interest
    of the employer.
  • Examples include travel to/from customer
    contacts, entertaining or being entertained to
    transact, discuss, or promote business, seminars
    or conferences

20
Travel Clarification
  • Not work related when
  • Employee is checking into a hotel, motel, or
    other temporary residence
  • Employee is on a personal detour from a
    reasonably direct route of travel (e.g., has
    taken a side trip for personal reasons)

21
Working at Home
  • Injuries/Illnesses that occur while an employee
    is working at home will be considered
    work-related if the injury/illness occurs while
    the employee is performing work for pay or
    compensation in the home, and the injury/illness
    is directly related to the performance of work
    rather than to the general home environment or
    setting.

22
New Recordables
  • Tuberculosis if evidenced by a positive skin test
    or diagnosed by a physician
  • Medical Removal Employee is removed from a
    their position under a medical removal provision
    in Title 8 regardless of the presence of
    diagnosis of an injury/illness. Must be recorded
    as days away from work or restricted work
    activity. Use column poisoning (e.g., benzene,
    cadmium, methylene chloride, lead, formaldehyde)

23
New Recordables Continued
  • Needlestick and Sharps Injuries
  • All work-related needlestick injuries and cuts
    from sharp objects that are contaminated with
    another persons blood or other potentially
    infectious material should be entered as an
    injury. To protect privacy, employees name may
    not be entered on OSHA 300 log instead enter
    privacy case.
  • If employee is diagnosed with an infectious
    bloodborne disease, update description and change
    classification from an injury to an illness
  • If employee is splashed with blood or OPIM,
    record if it results in a bloodborne illness

24
Definition
  • Privacy Concern Case
  • Injury/illness to an intimate body part or the
    reproductive system
  • Injury/illness resulting from a sexual assault
  • Mental illnesses
  • HIV Infection, hepatitis, or tuberculosis
  • Needlestick injuries and cuts from sharp objects
  • Illnesses in which an employee independently and
    voluntarily requests that his/her name not be
    entered on the log

25
Rules for Counting Lost Days
  • Count calendar days and cap at 180
  • Do not include day of injury
  • Stop counting if a physician release an employee
    to work but employee fails to show up
  • Special circumstances injury before vacation or
    weekend

26
Rules for Counting Restricted Days or Transfer
Days
  • Record if employee is kept from performing one or
    more routine duties
  • Do not have to record if restriction is only for
    day of injury
  • Recommended restrictions are only recorded if
    employee is kept from performing one or more
    routine job duties
  • A partial shift because of an injury is counted
    as a day of restriction
  • Stop counting if employees job has been
    permanently modified or changed
  • Count calendar days and cap at 180

27
3.0 Maintenance Retention of Records
  • Each department must maintain their own OSHA
    300s, 300As and 301s. Records must be maintained
    centrally but must be made available upon request
    to any employee, former employees, authorized
    employee representative, or Cal/OSHA inspector.

28
OSHA 300
  • Recordable entries must be made within seven (7)
    calendar days after receiving information that a
    recordable injury/illness has occurred.
  • Any changes to previous entries must also be made
    within seven (7) calendar days of dutiful
    knowledge of such a change.
  • The log must be kept complete and updated to
    within 45-calendar days.

29
OSHA 300 Continued
  • All log totals must be adjusted accordingly to
    reflect any changes.
  • Must be retained for 5 years and must be updated
    to include newly discovered recordable
    injuries/illnesses and any changes in
    classification of injury/illness
  • Send to City Safety Office at the beginning of
    each month

30
OSHA 300A
  • Total columns G M on OSHA 300 and transfer to
    300A at the end of the calendar year
  • Does not have to be updated during 5 year storage
  • Must be signed by City Safety Officer, City
    Manager, Assistant City Manager, or Deputy City
    Manager

31
OSHA 301
  • Departments must complete and file this form
    within seven (7) calendar days of receipt of
    information on a recordable injury or illness
  • May use 5020 in lieu of 301
  • Must be retained for five (5) years

32
4.0 Posting Requirements
  • Only Form 300A is posted
  • WHY Employee right to information
  • WHERE Conspicuous place or places where employee
    notices are customarily posted
  • WHEN From February 1 to April 30

33
Target Dates
  • Begin logging injuries/illnesses on 300 Log
    starting January 1
  • Use OSHA 200 Log for calendar year 2001

34
The End
  • Questions
  • Exercise
  • Thank you for attending!
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