OSHA

Recordkeepin
g Training
Scott Cole, SMS, CSP
[email protected]
Agenda
Review of Recordkeeping Forms
Presentation and Review
Incident Analysis
Questions and Answers

2
Forms
OSHA Form 300
◦ Log of Work-Related Injuries and
Illnesses
OSHA Form 301
◦ Injury and Illness Incident Report
OSHA Form 300A
◦ Summary of Work-Related Injuries and
Illnesses
PERRP Forms
◦ 300P, 301P, 300AP
3
This presentation is based on final revisions to
the Federal recordkeeping standard issued
January 19, 2001, and an addendum issued
July 3, 2001.

Note: In July 2003, PERRP announced

changes to its injury and illness recordkeeping
rule.
•Effective January 2005, Ohio public
employers must complete OSHA 300 series
injury and illness recordkeeping forms.

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OSHA Form 300
Recordkeeping
OSHA requires facilities to maintain
records of all work-related
recordable injuries and illnesses.

The employer has the ultimate

responsibility for making a good
faith determination about
recordability.

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OSHA 300 Recordability vs.
Workers' Compensation
Compensability
The requirements for recordability
should not be confused with
compensability.

Decisionsregarding recordability must

be made without regard to
compensability.

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Implementation
Requirements effective January 1,
2002.
The new rule replaces the existing
rule, the blue book, and the OSHA
letters of interpretation.

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Recording Criteria
Employers must record each fatality,
injury or illness that is:
◦ work-related; and
◦ a new case; and
◦ meets one or more of the general
recording criteria contained in
sections 1904.7-1904.12
The same recording criteria will be
applied to both injuries and illnesses,
i.e., no longer are all illnesses
recordable.

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 Recordkeeping Decision
Tree

Did the employee

No experience an injury
or illness?

Yes

Is the injury or
No illness work-
related?

Yes

Update the
Is the injury or previously recorded
No No
illness a new case? injury or illness
entry

Yes

Does the injury or

No illness meet the general Yes
recording criteria
Do not record
Record the injury
the injury or
or illness
illness
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Establishing Work
Relationship
Ifan event results in an injury/illness in
the work environment, it is presumed
work-related.
◦ A case is considered work-related if an event
or exposure in the work environment either
caused or contributed to the resulting
condition.
◦ A pre-existing injury or illness is considered
work-related if an event or exposure in the
work environment SIGNIFICANTLY aggravated
the condition.
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Establishing Work Relationship
(continued)
A pre-existing injury or illness is
significantly aggravated when an
event or exposure in the work
environment results in any of the
following:
◦ death
◦ loss of consciousness
◦ one or more days away from work,
or restricted days, or a job transfer
◦ medical treatment

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Work Relationship
Exceptions
Employee present as a member of the
general public (rather than employee).
Symptoms surface at work solely due to
non-work related event.
Voluntary participation in wellness
programs, medical, fitness, or
recreational activity.
Eating, drinking, or preparing food or
drink for personal consumption.

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 Work Relationship
Exceptions (continued)
Personal tasks outside assigned
working hours.
Personal grooming, self-medication for
a non-work related condition, or
intentionally self-inflicted.
Motor vehicle accident in company
parking lot / access road during
commutes.
Common cold or flu

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Key Definitions
New Case - the employee has not had a
recorded injury or illness of the same type
that affects the same part of the body, or
The employee previously had a recorded
injury or illness of the same type that
affected the same body part, but:
◦ had recovered completely, and
◦ an event caused the symptoms to
reappear

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Key Definitions (continued)
First Aid - is defined as anything
contained in a comprehensive,
specific list within the standard. This
is a complete list of all treatments
considered first aid.
First aid can be administered by a
physician, nurse, or other licensed
health care professional.
First Aid cases are not recordable.

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Key Definitions (continued)

Occupational Injury or Illness - any

abnormal condition or disorder.
Injuries include such cases as, but
not limited to, a cut, fracture, sprain
or amputation. Illnesses include
cases that are both acute and
chronic, such as , but not limited to,
a skin disease, respiratory disorder
or chemical poisoning.

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Key Definitions (continued)

Medical Treatment - the management

and care of a patient to combat
disease or disorder.
Does not include:
◦ visits to physician solely for
observation or counseling
◦ diagnostic procedures, e.g., X-rays
(negative), blood tests, prescriptions
used solely for diagnostic purposes,
e.g. eye drops to dilate pupils
◦ first aid cases
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Key Definitions (continued)
Recordable injury - a case is recordable
if the injury or illness results in:
◦ death
◦ days away from work
◦ restricted work or transfer to another
job
◦ medical treatment beyond first aid
◦ loss of consciousness

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Key Definitions (continued)
◦ Record a case if it involves a
significant injury or illness, diagnosed
by a licensed health care professional,
even if it does not result in death, days
away from work, restricted work or job
transfer, medical treatment beyond
first aid, or loss of consciousness.
Examples include:
 punctured eardrum
 fracture
 chronic irreversible disease
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General Recording Criteria
–
First Aid
Non prescription medication at non-
prescription strength
Tetanus immunizations
Cleaning, flushing, soaking surface
wounds
Wound coverings, butterfly bandages,
steri-strips
Hot or cold therapy (regardless of
number of applications)
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General Recording Criteria
- First Aid (continued)
Non-rigid means of support, e.g., ace
bandage
Temporary immobilization devices
used to transport accident victims
Drilling, toe or finger nails, draining
fluid from blister
Eye patches

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General Recording Criteria
- First Aid (continued)
Removing foreign bodies from eye with
only irrigation or cotton swab
Removing splinters/foreign material from
areas other than eye by irrigation,
tweezers, cotton swabs or other simple
means
Finger guards
Massages (not physical therapy)
Drinking fluids to relieve heat stress

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General Recording Criteria
- First Aid (continued)
Ifnot included on the first aid list, the
treatment is RECORDABLE

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General Recording Criteria
Prescription Medication
 Issuance of any prescription medication
(including single dose) is recordable. Even if:
◦ the employee does not take the prescription, or
◦ the employee does not fill it

 Overthe counter medication, e.g., ibuprofen,

given in prescription strength is recordable.

 Samplesof prescription medicine are

recordable.

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General Recording Criteria
- Burns
Only burns that receive medical
treatment are recordable. Therefore:
◦ the vast majority of 1st degree burns and
minor second degree burns will not be
recordable
◦ more serious 1st and 2nd degree burns that
receive medical treatment will be recordable
◦ 3rd degree burns are recordable

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General Recording Criteria
-
Hearing Loss Cases
Hearing loss cases are recordable
if there is a work-related shift in
hearing of an average of 10 dB or
more at 2,000, 3,000, and 4,000
Hz in one or both ears

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General Recording Criteria -
Bloodborne Pathogens
Recordable if:
◦ Needlesticks and cuts from sharp
objects, if contaminated with:
 another person’s blood; or
 OPIM
◦ Splashes or other exposures (not
cuts or scratches) if exposure
results in:
 Diagnosis of bloodborne illness (HIV,
Hepatitis)
 General recording criteria are met
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General Recording Criteria -
Musculoskeletal Disorders
Soft tissue cases are recordable only
if they are:
◦ work-related
◦ a new case
◦ meet one or more of the general
recording criteria
Check either the injury or illness
column as appropriate.

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General Recording Criteria
-
Tuberculosis
Record cases where:
◦ employees exposed to someone with
known case of active TB, and employee
subsequently develops a TB infection
 positive skin test
 diagnosis by physician or LHCP
◦ Record the case in the “respiratory
condition” column of the 300 Log

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General Recording Criteria
-
Tuberculosis (continued)
Do not record case when:
◦ employee living in household with
person diagnosed with active TB
◦ the public health department
identifies the worker as contact of an
individual with active TB
◦ a medical investigation shows the
employee’s infection was caused by
exposure away from work

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Medical Removal
If an employee is medically removed
(except voluntary removals below
required removal levels) from the work
environment under the medical
surveillance requirements of an OSHA
standard, record the case as:
◦ involving days away from work or
restricted work activity
◦ standards include lead, cadmium,
methylene chloride, formaldehyde and
benzene

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Distinguishing Between
Employees and Other
Workers
 Employers are required to maintain injury and
illness records for their own employees.

 Employers are not responsible for maintaining

records for employees of other firms or for
independent contractors.

 Key factor in determining who should record a

worker's injury or illness is "supervision." The
employer who generally supervises the day-to-
day activities is responsible for recording
injuries/illnesses.
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Location of OSHA Form 300
Each case must be linked with one
establishment
◦ an injury or illness experienced by an
employee is normally recorded on the log at
the employee’s home site
◦ if an injury or illness occurs to an employee
who is at another company site, record the
case at that site
◦ If an injury or illness occurs away from the
employees home site, i.e., not within the
company, record on the log where the
employee normally reports.

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Travel Status
To be on travel status, employees must
either be:
◦ outside their normal geographic area of
operation, or
◦ working off premises for more than a
normal workday (such as staying
overnight).
An employee's "normal geographic area
of operation" includes the town or city
where the employee normally works
and directly adjoining municipalities.

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Travel Status (continued)

When a traveling employee checks into a

hotel or motel, they establish a "home
away from home".

An injury/illness would not be recordable

if it occurred during normal living
activities, e.g., eating, sleeping,
recreation, etc., or if the employee
deviates from a reasonably direct route
of travel.

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Travel Status (continued)
Employees who travel on company
business shall be considered to be
engaged in work-related activities all the
time they spend in the interest of the
company, including, but not limited to,
travel to and from customer contacts and,
entertaining for the purpose of transacting,
discussing, or promoting business.

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General Recording Criteria
-
Lost Workday Cases
• Lost workday cases are those cases resulting in
days lost from work of injury or illness.
• The number of days away from work does not
include the day of injury, or the onset of illness.
• Count the number of calendar days the
employee was unable to work, regardless of
whether the employee was scheduled to work.
• Weekend days, holidays, and vacation days, or
other days off, e.g., temporary plant closing, are
included in the total number of lost workdays
recorded if the employee was not able to work.

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General Recording Criteria
-
Lost Workday Cases
(continued)
The total days away from work are
“capped” at 180 calendar days.

Stop counting days away from work if the

employee leaves the company for some
reason unrelated to the injury or illness,
such as retirement, permanent plant
closing, or to take another job.

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General Recording Criteria
-
Restricted Work Activity
The emphasis on determining
restricted activity is the employee's
ability to perform all of his or her
routine functions during all of his or
her normal workday or shift.

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General Recording Criteria
-
Restricted Work Activity
(continued)
An employee’s routine functions are
those work activities the employee
regularly performs at least once
per week.

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General Recording Criteria
-
Restricted Work Activity
(continued)
Restricted work occurs when, as a
result of a work-related injury or
illness:
◦ the employer, physician or other LHCP, keeps
the employee from performing one or more
of the routine functions of his or her job, or
from working the full workday that he or she
would otherwise have been scheduled to
work; or
◦ you assign an employee to a job other than
his or her regular job
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General Recording Criteria
-
Restricted Work Activity
(continued)
Days of restricted work are counted
in the same way as lost workdays.

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Log Entry Time
Requirements
Employers must enter each recordable
case on the appropriate forms within 7
calendar days of receiving information
that a recordable case occurred.

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Retention and Updating
Keep forms for the current year
plus 5 previous years.

Must update the OSHA Form 300

during the retention period.

DO NOT need to update the

OSHA Form 300A or 301.

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Privacy Concern Cases
Finite list:
◦ HIV infection, hepatitis, tuberculosis
◦ recordable needlestick and sharps injuries
◦ mental illness
◦ injury or illness involving sexual assault
◦ injury or illness to the reproductive system
◦ employee requests to keep name off

Employer may use discretion in “description”

portion of log if employee can still be
identified

45
Privacy Issues
Do not enter the employee’s name
on the OSHA Form 300 for “privacy
concern cases”.

Write “privacy concern” in the name

column.

Keep a separate confidential list of

the case numbers and employee
names.
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Annual Summary
Review OSHA Form 300 for accuracy.
Complete OSHA Form 300A.

Certify Summary (signed by company

executive).

Post the Form 300A summary

February 1 through April 30 in a
conspicuous place(s) where notices
to employees are customarily
posted.
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Annual Summary (continued)
A company executive must certify
that:
◦ they have examined the log
◦ they reasonably believe, based on
personal knowledge of the
recordkeeping process, that the
summary is accurate and complete

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Annual Summary (continued)
A company executive certifying
the summary must be one of the
following:
◦ an officer of the corporation
◦ the highest ranking company official
working at the establishment
◦ The immediate supervisor of the
highest ranking official on site

49
Record Access to Government
Employees
Provide copies of records kept
under 1904 within 4 business
hours to:
◦ a representative of OSHA conducting
the inspection
◦ a representative of a State agency
administering portions of a State
plan
◦ a representative of NIOSH
conducting an investigation
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Employee Involvement
You must inform each employee of
the process to report an injury or
illness to management. This
means:
◦ set up a system for reporting
◦ inform each employee of the system

51
Employee Involvement
(continued)
Must provide access to injury and
illness records to employees,
former employees, their personal
representatives and authorized
employee representatives.

52
Employee Involvement
(continued)
Access Rules:
◦ provide copy of OSHA Form 300 by
end of next business day. May not
remove names except for privacy
concern cases.
◦ provide copy of their own OSHA
Form 301 to employees, and former
employees, or their personal
representatives by the end of the
next business day.

53
Fatality/Catastrophe
Reporting
Report orally to OSHA within 8 hours, any
work-related fatality or incident involving 3
or more in-patient hospitalizations (notify
local office, or if no answer call 1-800-321-OSHA
(6742).
◦ You must only report each fatality or multiple
hospitalization incident that occurs within 30 days of an
incident, e.g., death that occurs 60 days after incident
does not need to be reported.

Must report fatal heart attacks.

Do not need to report:

◦ public street motor vehicle accidents (outside of
construction zone)
◦ commercial airplane, train, subway, or bus
accidents
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Fatality/Catastrophe
Reporting (continued)
You must provide OSHA with the following:
◦ establishment name
◦ location of the incident
◦ time of the incident
◦ the number of fatalities or hospitalized
employees and their names
◦ the site contact person and phone
number
◦ a brief description of the incident

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Questions Thus Far?

56
Case Study 1
An employee is removing a tool from an elevated work
surface. The employee falls, injuring the right knee.
The employee is sent to the hospital for an examination
which results in a diagnosis of a right knee sprain.

The employee does not return to work for three days.

57
Case Study 2
An employee is walking from a vehicle into the plant
entrance. The employee falls, injuring the left hip. The
employee is escorted to the hospital for an examination.
X-rays are taken. The x-rays are negative. Diagnosis is
a left hip contusion.

Work restrictions are no standing for greater than 4

hours.

The employee returns to work after the examination.

58
Case Study 3
An employee is walking from their vehicle into the
plant entrance when something enters the employee’s
right eye. The employee enters the plant and uses an
eyewash station to remove the debris.

59
Case Study 4
An employee is working on a hydraulic system. A
hydraulic line fails, releasing hydraulic fluid which
enters the employee’s left eye. The employee uses an
eyewash station to remove the contaminant but is
unsuccessful. The employee is escorted to the hospital
where a doctor uses drip irrigation for 4 hours.

The employee returns to work the next day.

60
Case Study 5
A sales employee is walking into a customer’s plant
when she slips and falls. The employee is escorted to a
local hospital. The employee has a right knee sprain.

There are no work restrictions.

The employee is given a 7-day sample of an anti-

inflamatory medication.

The employee returns to work the next day.

61
Case Study 6
An employee is traveling to the Ohio Safety Congress
in Columbus, Ohio.

The employee is involved in a vehicle accident.

The employee receives medical attention from an EMT

at the scene of the accident for a laceration to the right
forearm.

62
Case Study 7
An employee is pulling wire through conduit when he
falls off of a step-ladder, injuring his left foot. The
employee does not report the injury immediately.

Three days later, the employee reports that they went to

the hospital the previous evening due to the left foot
injury. The employee states that they did not think
anything of it at the time but that the pain has not gone
away in three days.

The employee is diagnosed with a fractured left foot.

The employee has surgery and does not return to work

for 207 days. Upon return, the employee has work
restrictions for 395 days. 63
Case Study 8
An employee is closing a large gate valve when the
employee’s hand slips causing contact with the valve
handle and a laceration of the employee’s left forearm.

The employee is escorted to the hospital and receives

irrigation, steri-strips, a sterile wrap and a tetanus shot.

The employee returns to work with a work restriction

of keeping the bandage clean and dry.

64
Case Study 9
An employee is missing from the production floor for
an hour before another employee reports them MIA.
The employee is found in the bathroom where they
seem to be sick.

The employee is escorted to the hospital via

ambulance.

Upon medical evaluation, the employee is diagnosed

with a diabetic attack.

The employee returns to work the next day.

65
Case Study 10
An employee cuts their hand with a utility knife while
opening a package.

The employee uses supplies from the plant’s first aid

kit.

66
Questions?

67