NEW OSHA RECORDKEEPING STANDARD Prepared by: Hettrick, Cyr & Associates, Inc.

BENEFITS OF THE RULE Improves employee involvement Improves employee involvement Creates simpler forms Creates simpler forms Provides clearer regulatory requirements Provides clearer regulatory requirements Increases employers flexibility to use computers Increases employers flexibility to use computers

DAY COUNTS Eliminates the term lost workdays and focuses on days away or days restricted or transferred Eliminates the term lost workdays and focuses on days away or days restricted or transferred Includes new rules for counting that rely on calendar days instead of workdays Includes new rules for counting that rely on calendar days instead of workdays

RECORDING CRITERIA Eliminates different criteria for recording work-related injuries and work-related illnesses Eliminates different criteria for recording work-related injuries and work-related illnesses Former rule required employers to record all illnesses, regardless of severity Former rule required employers to record all illnesses, regardless of severity

LOG REPORTING CHANGES NEW 300 log simplified NEW 300 log simplified Supplementary Record (OSHA 301) Supplementary Record (OSHA 301) Annual Summary (OSHA 300A); 3 Month Posting – 2/1 thru 4/30 Annual Summary (OSHA 300A); 3 Month Posting – 2/1 thru 4/30 Signed By Company Executive Signed By Company Executive Access to OSHA 301 for Employee Representatives (without personal identifiers) Access to OSHA 301 for Employee Representatives (without personal identifiers) All Entries Within 7 Calendar Days All Entries Within 7 Calendar Days Day count by calendar days;180 days maximum Day count by calendar days;180 days maximum Lost Work Day language eliminated Lost Work Day language eliminated NEW FORMS MUST BE USED BEGINNING 1/1/2002

RECORDING CRITERIA DECISION TREE

WORK RELATEDNESS Cases are work-related if: Cases are work-related if: –An event or exposure in the work environment either caused or contributed to the resulting condition –An event or exposure in the work environment significantly aggravated a pre-existing injury or illness

WORK RELATED EXCEPTIONS Adds additional exceptions to the definition of work relationship to limit recording of cases involving: Adds additional exceptions to the definition of work relationship to limit recording of cases involving: –eating, drinking, or preparing food or drink for personal consumption –common colds and flu –voluntary participation in wellness or fitness programs –personal grooming or self-medication

OSHA RECORDABLES Death Death Loss of consciousness Loss of consciousness Days away from work Days away from work Restricted work activity or job transfer Restricted work activity or job transfer Medical treatment beyond first aid Medical treatment beyond first aid Significant work related injuries/illnesses as defined by physician Significant work related injuries/illnesses as defined by physician Additional criteria Additional criteria

RECORDING NEEDLESTICKS Requires employers to record all needlestick and sharps injuries involving contamination by another persons blood or other potentially infectious material Requires employers to record all needlestick and sharps injuries involving contamination by another persons blood or other potentially infectious material

HEARING LOSS Requires employers to record 25 dB shifts in employees hearing during 2002 Requires employers to record 25 dB shifts in employees hearing during 2002 OSHA will reconsider the hearing loss criteria for 2003 and beyond OSHA will reconsider the hearing loss criteria for 2003 and beyond

MUSCULOSKELETAL DISORDERS Applies the same recording criteria to musculoskeletal disorders (MSDs) as to all other injuries and illnesses Applies the same recording criteria to musculoskeletal disorders (MSDs) as to all other injuries and illnesses Employer retains flexibility to determine whether an event or exposure in the work environment caused or contributed to the MSD Employer retains flexibility to determine whether an event or exposure in the work environment caused or contributed to the MSD OSHA will use the one-year delay to develop definitions of ergonomic injury and MSD consistent with a comprehensive effort OSHA will use the one-year delay to develop definitions of ergonomic injury and MSD consistent with a comprehensive effort

TUBERCULOSIS & MEDICAL REMOVAL Includes separate provisions describing the recording criteria for cases involving the work-related transmission of tuberculosis Includes separate provisions describing the recording criteria for cases involving the work-related transmission of tuberculosis Requires employers to record cases of medical removal under OSHA standards Requires employers to record cases of medical removal under OSHA standards

FIRST AID NON RECORDABLES, Application of Antiseptics during first visit to medical personnel Application of Antiseptics during first visit to medical personnel Treatment of First Degree Burns Treatment of First Degree Burns Application of Bandages during any visit to medical personnel Application of Bandages during any visit to medical personnel Use of Elastic Bandages during first visit to medical personnel Use of Elastic Bandages during first visit to medical personnel Removal of Foreign Bodies from wound; if procedure is uncomplicated, and is, for example, by tweezers or other simple technique Removal of Foreign Bodies from wound; if procedure is uncomplicated, and is, for example, by tweezers or other simple technique Use of Non Prescription Medication and administration of single dose of Prescription Medication on first visit for minor injury or discomfort Use of Non Prescription Medication and administration of single dose of Prescription Medication on first visit for minor injury or discomfort Soaking Therapy on initial visit to medical personnel or removal of bandages by Soaking Application of hot or cold Compresses during first visit to medical personnel Application of Ointments to abrasions to prevent drying or cracking Application of Heat Therapy during first visit to medical personnel Negative X-Ray diagnosis Observation of injury during visit to medical personnel Administration of Tetanus Shots or Boosters without serious injury

FIRST AID NON RECORDABLES, 1/1/2002 Using non-prescription medications at non-prescription strength Using non-prescription medications at non-prescription strength Administering tetanus immunizations Administering tetanus immunizations Cleaning, flushing, or soaking wounds on the skin surface Cleaning, flushing, or soaking wounds on the skin surface Using wound coverings, such as bandages, BandAids, gauze pads, etc., or using SteriStrips or butterfly bandages Using wound coverings, such as bandages, BandAids, gauze pads, etc., or using SteriStrips or butterfly bandages Using hot or cold therapy Using hot or cold therapy Using any totally non-rigid means of support, such as elastic bandages, wraps, non- rigid back belts, etc. Using any totally non-rigid means of support, such as elastic bandages, wraps, non- rigid back belts, etc. Using temporary immobilization devices while transporting an accident victim (splints, slings, neck collars, or back boards) Drilling a fingernail or toenail to relieve pressure, or draining fluids from blisters Using eye patches Using simple irrigation or a cotton swab to remove foreign bodies not embedded in or adhered to the eye Using finger guards

FIRST AID NON RECORDABLES, 1/1/2002 Using irrigation, tweezers, cotton swab, or other simple means to remove splinters or foreign material from areas other than the eye Using irrigation, tweezers, cotton swab, or other simple means to remove splinters or foreign material from areas other than the eye Using massages (physical therapy or chiropractic treatment considered medical treatment under new standard) Using massages (physical therapy or chiropractic treatment considered medical treatment under new standard) Drinking fluids to relieve heat stress Drinking fluids to relieve heat stress THIS IS A COMPLETE LIST OF ALL TREATMENTS CONSIDERED FIRST AID, NON-RECORDABLE

MEDICAL TREATMENT RECORDABLES Treatment of Infection Treatment of Infection Application of Antiseptics during second or subsequent visit to medical personnel Application of Antiseptics during second or subsequent visit to medical personnel Treatment of Second or Third Degree Burns Treatment of Second or Third Degree Burns Application of Sutures (Stitches) Application of Sutures (Stitches) Application of Butterfly Adhesive Dressings or Steri Strips in lieu of sutures Application of Butterfly Adhesive Dressings or Steri Strips in lieu of sutures Removal of Foreign Bodies Embedded in Eye Removal of Foreign Bodies Embedded in Eye Removal of Foreign Bodies from Wound; if procedure is complicated because of depth of embedment, size, or location Removal of Foreign Bodies from Wound; if procedure is complicated because of depth of embedment, size, or location Use of Prescription Medications (except a single dose administered on first visit for minor injury or discomfort Use of Prescription Medications (except a single dose administered on first visit for minor injury or discomfort Use of hot or cold Soaking Therapy during second or subsequent visit to medical personnel Application of hot or cold Compresses during second or subsequent visit to medical personnel Cutting away Dead Skin (surgical debridement) Application of Heat Therapy during second or subsequent visit to medical personnel Use of Whirlpool Bath Therapy during second or subsequent visit to medical personnel Positive X-Ray diagnosis (fractures, broken bones, etc.) Admission to a Hospital or equivalent medical facility for treatment

MEDICAL TREATMENT The Management and Care of a Patient to Combat Disease or Disorder Not Considered Medical Treatment: Visits to a doctor or health care professional solely for observation or counseling Visits to a doctor or health care professional solely for observation or counseling The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils; or The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils; or First Aid as defined in the new standard First Aid as defined in the new standard

EMPLOYEE PRIVACY Prohibits employers from entering an individuals name on Form 300 for certain types of injuries/illnesses Prohibits employers from entering an individuals name on Form 300 for certain types of injuries/illnesses Provides employers the right not to describe the nature of sensitive injuries where the employees identity would be known Provides employers the right not to describe the nature of sensitive injuries where the employees identity would be known Gives employee representatives access only to the portion of Form 301 which contains no personal information Gives employee representatives access only to the portion of Form 301 which contains no personal information Requires employers to remove employees names before providing the data to persons not provided access rights under the rule Requires employers to remove employees names before providing the data to persons not provided access rights under the rule

PRIVACY CASE ENTRIES Injury or illness to an intimate body part or to reproductive system Injury or illness to an intimate body part or to reproductive system Injury or illness resulting from sexual assault Injury or illness resulting from sexual assault A mental illness A mental illness HIV infection, hepatitis, or TB HIV infection, hepatitis, or TB A needlestick or sharps contaminated by blood or infectious material A needlestick or sharps contaminated by blood or infectious material Voluntary employee request of illness case Voluntary employee request of illness case RECORD PRIVACY CASE IN NAME COLUMN

EMPLOYEE INVOLVEMENT Requires employers to establish a procedure for employees to report injuries and illnesses and tell their employees how to report Requires employers to establish a procedure for employees to report injuries and illnesses and tell their employees how to report Employers are prohibited from discriminating against employees who do report Employers are prohibited from discriminating against employees who do report Employee representatives will now have access to those parts of the OSHA 301 form relevant to workplace safety and health Employee representatives will now have access to those parts of the OSHA 301 form relevant to workplace safety and health

REPORTING TO OSHA Changes the reporting of fatalities and catastrophes to exclude some public transportation and motor vehicle accidents, but adds heart attack fatalities Changes the reporting of fatalities and catastrophes to exclude some public transportation and motor vehicle accidents, but adds heart attack fatalities