Recordkeeping

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Recordkeeping

• MODULE 8

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OSHA Information Resources

• OSHA Recordkeeping page (cached)
• Forms (PDF and XLS)
• Also in back of CFR book
• Recordkeeping Handbook

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29 CFR 1904.0 Purpose

• Require employers to record and report
  work-related fatalities, injuries and illnesses
• Data used to direct OSHA programs
• Data used in employer safety programs
• Aggregated in BLS Annual Survey of Occupational
  Injuries and Illnesses

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Scope

• 1904.1 Exemption for ?10 employees
• In entire company, at any time during year
• Unless OSHA or BLS requires in writing
• Must report fatality or ?3 hospitalized
• 1904.2 Exemption for certain industries
• Low hazard industries by SIC code
• 1904.3 Records for ?1 agency

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Definitions

• 1904.46
• The Act
• Establishment
• Injury or illness
• Physician or Other Licensed Health Care
  Professional
• You

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1904.4 Recording Criteria

• Record each fatality, injury, or illness
• Work related (1904.5) and
• New case (1904.6) and
• Meets criteria in 1904.7-12

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Subtitles Transitions
Did the employee experience an injury or illness?
YES
YES
NO
UPDATE PREVIOUS RECORD
YES

• FOR EXAMPLE

Does the injury or illness meet the general
criteria or the application to specific cases?
YES
RECORD THE INJURY OR ILLNESS
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1904.5 Work-Relatedness

• Basic requirement (a)
• Implementation (b)
• Work environment?
• At work but not work-related?
• Significantly aggravated?
• Pre-existing condition?
• Travel status?
• Working at home?

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1904.6 New Cases

• Basic requirement
• No previously recorded similar case, or
• Recovered completely.
• Implementation
• Recurrence of chronic illness?
• First signs/symptoms?
• Physician advice?

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1904.7 Recording Criteria

• Basic requirement results in
• Death
• Days away from work
• Restricted work or job transfer
• Medical treatment beyond first aid
• Loss of consciousness
• Significant diagnosed injury or illness
• Implementation / Questions

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1904.8 Needlesticks and Sharps

• Record if contaminated with
• Blood or
• Potentially Infectious Material
• Do not record employees name

12
1904.9 Medical Removal

• Record medical removals under other OSHA
  standards
• Not if removed voluntarily before overexposure

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1904.10 Hearing Loss

• Work-related STS in at least 1 ear
• Total hearing 25 dB above audiometric zero in
  same ear(s)

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1904.29 Forms

• 300 Log, 300-A Summary, 301 Incident Report
• Equivalent forms
• Privacy concern cases
• Voluntary disclosure

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1904.30 Multiple Business Establishments

• Separate logs if in operation ?1 year
• May combine short-term on one log
• May keep centrally if promptly updated and
  available
• Each employee linked with an establishment
• Record at location of occurrence

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1904.31 Covered Employees

• All on payroll, any status
• Non-payroll employees if supervised day to day
• Owner/partners not included

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1904.32 Annual Summary

• Review at end of calendar year
• Certify and post annual summary
• 300-A or equivalent form

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1904.33 Retention and Updating

• Save all forms for 5 years
• Update for new discoveries or changes
• 1904.34 Transfer to new owner

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1904.35 Employee Involvement

• Inform each employee of how to report
• Provide employees limited access to records
• 1904.36 Prohibition against discrimination

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Equivalent systems

• 1904.37 State recordkeeping regulations
• 1904.38 Variances from recordkeeping rule for
  alternative system

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1904.39 Reporting fatalities and multiple
hospitalizations

• Orally report within 8 hours of death or
  hospitalization of ?3 employees

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Providing records to government

• 1904.40 Provide within 4 hours or authorized
  government representative request
• 1904.41 Return annual survey form if received
• 1904.42 Return BLS survey form if received