The New OSHA Recordkeeping Issue: Do You have to Send in your Information and Will it be a Public Record. Sept 19, 2017 10:30 am Seattle, WA. Rick Gleason, CSP, CIH rgleason@uw.edu (206) 856-6660

Keep Everyone Safe!!

rgleason@uw.edu 206-856-6660

There is a big difference between -Recording -Reporting -Workers Compensation Don’t Confuse the three

We have always used the OSHA Recordable numbers to compare States and Companies

Have total OSHA Recordable cases gone up, down or stayed the same over the last 30 years?

Recordable Cases, 1973-1997

Has the Occupational Illness rate gone up, down or stayed the same in the last 25 years?

Incident Rate for Illnesses, 75-96

Incident Rate by State, 1997, 7.1 average Construction?

WA. State Injury and Illness Rate Year. Total WA. State Injury and Illness Rate Year Total Lost Days Medical only 2016 4.5 2.4 2.1 2005 6.4 2.9 3.5 2000 8.3 3.5 4.8 1997 9.8 3.2 6.6

The new rule, which takes effect Jan The new rule, which takes effect Jan. 1, 2017, requires certain employers to electronically submit injury and illness data that they are already required to record on their onsite OSHA Injury and Illness forms. The information will be on OSHA’s Public website just like inspection data

"Our new rule will 'nudge' employers to prevent work injuries to show investors, job seekers, customers and the public they operate safe and well-managed facilities. Access to injury data will also help OSHA better target compliance assistance and enforcement resources, and enable 'big data' researchers to apply their skills to making workplaces safer.“ Dr. David Michaels, Assistant Secretary of Labor for Occupational Safety and Health

OSHA: New Electronic Workplace Accident Reporting Rules “Improve Tracking of Workplace Injuries and Illnesses” § 1904.35(b)(1)(iv). Referred to as “Electronic Reporting Rule” because effective 1/1/17 employers will be required to submit electronically their recordkeeping forms about injuries and illnesses. Employers with 10 or more employees must keep records of workplace injuries and illnesses. Before the new rule, employers only had to submit the records if OSHA asked. Now, employers with 250 or more employees must submit annually. OSHA will publish electronically submitted data (without personally identifiable information such as employee names, etc.)

Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Form 300A by July 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

High Risk Industries 20-249 employers must submit 300A by July 1, 2017

OSHA State Plan states must adopt requirements that are substantially identical to the requirements in this final rule within 6 months after publication of this final rule.

When the BLS gathers data it is not posted by employer but by type of industry.

Establishment Specific Injury & Illness Data (OSHA Data Initiative) The Occupational Safety and Health Administration (OSHA) collected work-related injury and illness data from employers within specific industry and employment size specifications from 1996 through 2011 or about 15 years.

Some data already accessible on OSHA’s website TCR: Total Case Rate per 100 full time workers per year DART: Days Away, Restricted or Transfer cases

In order to ensure the completeness and accuracy of injury and illness data collected by employers and reported to OSHA, the final rule also: 1. requires employers to inform employees of their right to report work-related injuries and illnesses free from retaliation; 2. clarifies the existing implicit requirement that an employer's procedure for reporting work-related injuries and illnesses must be reasonable and not deter or discourage employees from reporting; and 3. incorporates the existing statutory prohibition on retaliating against employees for reporting work-related injuries or illnesses.

Current OSHA Recordable rate averages 3 Current OSHA Recordable rate averages 3.3 per 100 workers per year Current Fatality rates in USA is 3.3/100,000 per year. Thus for every 1000 OSHA Recordables there is 1 fatality

Remember Heinrich’s Triangle

OSHA Triangle 1 Fatality 1000 OSHA Recordables (Medical Treatment beyond First Aid) 10,000 First Aid Cases 1,000,000 Near Misses

Questions How does recordkeeping relate to Prohibiting Mandatory Drug Testing? 1:30 pm tomorrow at the Gov. Safe Conf.

Questions