Department of Defense Voluntary Protection Programs Center of Excellence Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense Department of Defense Voluntary Protection Programs Center of Excellence Recordkeeping Decision-Making Process Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense

Objectives After this presentation, you will be able to: –Maintain accurate injury and illness records –Complete the e-VPP Action Plan Hazard Analysis element – Occupational Health Care Program & Recordkeeping –Conduct more comprehensive incident investigations –Identify recordable mishap trends.

OSHA Injury and Illness Recordkeeping There is a 5 step process to OSHA Injury and Illness Recordkeeping

Step 1 Scenarios Scenario B: There is a chlorine gas leak at the base swimming pool and two (2) employees in the area are rushed to the hospital. They are told to stay home the next day as a precautionary measure. Scenario A: After working seven hours entering computer data a worker reports a complaint of painful wrists. The employee is given 2 Excedrin™ at the base clinic and returns to the job. Stop Here OR Go On To The Next Step?

Step 1 Scenarios Scenario B: There is a chlorine gas leak at the base swimming pool and two (2) employees in the area are rushed to the hospital. They are told to stay home the next day as a precautionary measure. Scenario A: After working seven hours entering computer data a worker reports a complaint of painful wrists. The employee is given 2 Excedrin™ at the base clinic and returns to the job. Stop Here OR Go On To The Next Step? It Depends! Return to Step 1 Scenarios

Step 2 YES! Return to Step 1 Scenarios

Determination of Work-Relatedness An injury or illness must be considered work- related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures in the work environment unless an exception specifically applies.

Non-Work Related Situations 1.If there is no discernable cause the injury/illness did not result from event/exposure at work. 2.At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee. 3.The injury or illness involves signs or symptoms that surface at work but result solely from a non- work related event or exposure that occurs outside the work environment.

Non-Work Related Situations 4.The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball. 5.The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption (whether bought on the employer’s premises or brought in), i.e. the employee is injured by cutting his sandwich while eating lunch in the employer’s establishment.

Non-Work Related Situations 6.The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee’s assigned working hours. 7.The injury or illness is solely the result of personal grooming, self medication for a non-work-related condition, or is intentionally self-inflicted. 8.The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work.

Non-Work Related Situations 9.The illness is the common cold or flu (Note: contagious diseases such as tuberculosis, brucellosis, hepatitis A, or plague are considered work-related if the employee is infected at work). 10.The illness is a mental illness. Mental illness will not be considered work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related.

Step 2 Scenarios Stop Here OR Go On To The Next Step? Scenario A: Employee sprains ankle in company parking lot on their way in to work. Scenario B: Employee slips and falls in hallway, breaking an arm while working on son’s science project on the employee’s day off.

Step 2 Scenarios Stop Here OR Go On To The Next Step? Scenario A: Employee sprains ankle in company parking lot on their way in to work. Scenario B: Employee slips and falls in hallway, breaking an arm while working on son’s science project on the employee’s day off. It Depends! Return to Step 2 Scenarios

OSHA Recordability and Workers’ Compensation Workers’ Compensation determinations do NOT impact OSHA recordability: – Some cases may be OSHA recordable and compensable – Some cases may be compensable, but not OSHA recordable – Some cases may be OSHA recordable, but not compensable.

Step 3 YES! Return to Step 2 Scenarios YES!

Determination of New Case Consider an injury or illness a “new case” if the employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body. Employee previously experienced a recorded injury or illness of the same type that affected the same part of body but had recovered completely (all signs and symptoms had disappeared) and an event or exposure in the work environment caused the signs or symptoms to reappear.

Step 3 Scenarios Stop Here OR Go On To The Next Step? Scenario A: Five (5) weeks ago, employee sprained wrist at work and received support, prescription medication, and “light duty”. Two weeks ago employee was back on normal job. Today (5 weeks after the injury) employee complains of pain in same wrist after moving boxes. Scenario B: Five(5) weeks ago, employee sprained wrist at work and received support, prescription medication, and “light duty”. Two weeks ago employee was back on normal job. Today (5 weeks after the injury) employee complains of pain in same wrist after moving boxes. Employee continues to take prescription medications for pain throughout this period of time. Scenario C: Employee fractures foot at work. Every six months or so it bothers him and he is placed on light duty for a day or two.

Step 3 Scenarios Stop Here OR Go On To The Next Step? Scenario A: Five (5) weeks ago, employee sprained wrist at work and received support, prescription medication, and “light duty”. Two weeks ago employee was back on normal job. Today (5 weeks after the injury) employee complains of pain in same wrist after moving boxes. Scenario B: Five(5) weeks ago, employee sprained wrist at work and received support, prescription medication, and “light duty”. Two weeks ago employee was back on normal job. Today (5 weeks after the injury) employee complains of pain in same wrist after moving boxes. Employee continues to take prescription medications for pain throughout this period of time. Scenario C: Employee fractures foot at work. Every six months or so it bothers him and he is placed on light duty for a day or two. Return to Step 3 Scenarios STOP! It Depends!

Step 4 YES! Return to Step 3 Scenarios YES!

General Recording Criteria An injury or illness meets general recording criteria and is recordable if it results in: – Death – Days away from work, restricted work or transfer to another job – Medical treatment beyond first aid or – Loss of consciousness Injury and illness cases diagnosed by a physician or other licensed health care professional are still recordable, even if they do not meet the above results.

Step 5 YES! Return to Step 4 Scenarios YES!

Day Counts Count the number of calendar days the employee was away from work or restricted/transferred (include weekend days, holidays, vacation days, etc.) Cap the day count at 180 days away and/or days restricted. Stop the day count if employee leaves company for a reason unrelated to the injury or illness. Must estimate day count when employee leaves company due to reasons related to the injury and illness.

Medical Treatment vs First Aid Medical treatment DOES NOT include: – Visits to a physician or other licensed health care professional (PLHCP) solely for observation or counseling only – Diagnostic procedures – First aid.

Medical Treatment vs First Aid Any item not included on the First Aid list is classified as “Medical Treatment” First aid includes: –Using temporary immobilization devices while transporting an accident victim –Drilling a nail –Using eye patches –Any number of hot or cold treatments –Administering tetanus immunizations –Cleaning, flushing or soaking wounds on the surface of the skin.

Medical Treatment vs First Aid First aid also includes: –Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means –Taking over-the-counter medications at non-prescription strength –Drinking fluids for relief of heat stress –Using any non-rigid means of support, as elastic bandages, wraps, back belts, etc. –Using wound coverings and closures –Using finger guards –Using massages.

Medical Treatment vs First Aid Even 1 dose of prescription medication is considered “Medical Treatment” Any over-the-counter (OTC) medication at prescription strength is “Medical Treatment”. OTC MedicationBrand NameQuantity IbuprofenAdvil ™> 467 mg DiphenhydramineBenadryl ™> 50 mg Naproxen sodiumAleve ™> 220 mg KetoprofenOrudus KT ™> 25 mg

Significant Diagnosed Injury or Illness An injury or illness that is automatically recordable if work related: – Fracture of bones or teeth – Punctured ear drum – Cancer – Chronic irreversible disease (e.g., silicosis).

Determining Case Severity Employee has a work-related injury or illness, sees doctor, told she can only work on light duty for the next two weeks. Normally scheduled for five day workweeks. How many days of restricted work activity should be entered on the OSHA Log?

Hearing Loss Recordability OSHA’s recordkeeping rule requires the employer to record all work-related hearing loss cases that meet BOTH of the following conditions on the same audiometric test for either ear: – The employee has experienced a Standard Threshold Shift (STS) – The employee’s total hearing level is 25 dB or more above audiometric zero (averaged at 2000, 3000, & 4000 Hz) in the same ear(s) as the STS.

Bloodborne Pathogen Recordability ALL needlesticks and sharps injuries that are contaminated with another person’s blood or other potentially infectious material are recordable. Record splashes or other exposures to blood or other potentially infectious material if it results in diagnosis of a bloodborne disease or meets the general recording criteria.

OSHA Forms Employers may elect to use the OSHA 300 and 301 forms to meet the sharps injury log requirements, provided two conditions are met: – The employer must enter the type and brand of the device on either the 300 or 301 form – The employer must maintain the records in a way that segregates sharps injuries from other types of work-related injuries and illnesses, or allows sharps injuries to be easily separated.

OSHA Forms OSHA Form 300, Log of Work-Related Injuries and Illnesses OSHA Form 300A, Summary of Work- Related Injuries and Illnesses OSHA Form 301, Injury and Illness Incident Report.

Covered Employees Employees on payroll Employees not on payroll who are supervised on a day-to-day basis Temporary help agencies should not record the cases experienced by temp workers who are supervised by installation personnel.

Annual Summary – OSHA 300A Federal establishments certification –The senior establishment management official –The head of the Agency for which the senior establishment management official works, or –Any management official who is in the direct chain of command between the senior establishment management official and the head of the agency head Must post for 3-month period from February 1 to April 30 of the year following the year covered by the summary.

Reporting Information to the Government Fatality and catastrophe reporting Access for Government representatives.

VPP Assistance This training can be used as part of your site’s documentation of action taken to address the following VPP actions: –Hazard Prevention & Control Occupational Health Care Program –Safety and Health Training Recordkeeping S&H Training for Staff and Others Assigned with S&H Responsibilities –Conducting an Assessment of Workplace S&H Practices –Trend Analysis –Hazard Elimination and Control Methods.

For More Help OSHA’s Recordkeeping Page: ml ml OSHA Regional Recordkeeping Coordinators.

Summary In this session you learned about: –Accurate injury and illness records –Requirements for reporting and retaining injury and illness records –Comprehensive incident investigations –Trending recordable mishaps.