OSHA Recordkeeping Employment Relations Division Occupational Safety and Health Bureau

“Just because the numbers are good doesn’t mean anything. There are three ways to continuously improve performance numbers. One is to continuously improve processes, one is to get lucky, and the other is to lie. If you aren’t dedicated to improving processes, you’re doing one of the other two.” o Dr. W. Edwards Deming Author and Consultant.

Identify the OSHA requirements for recordkeeping, posting and reporting Acquire an understanding of the OSHA 300, 300A and 301.

Required since 1971 Key provisions of the OSHA rules for recording injury and illness cases 29 CFR 1904 new in 2002, changed in 2003 (hearing loss), and again in 2004 (form update) Rumored changes in 2010 National Emphasis for 2009

The system is simpler and provides better resources than the old system Greater employer flexibility determining recordability Some aspects reduce ORIs, some increase ORI’s Day counts are not comparable to previous years due to changes

If your company had 10 or fewer employees at all times during the last calendar year, you do not need to keep the injury and illness records unless surveyed by OSHA or BLS The size exemption is based on the number of employees in the entire company Include temporary employees who you supervised on a day to day basis in the count

All industries in agriculture, construction, manufacturing, transportation, utilities and wholesale trade sectors are covered In the retail and service sectors, some industries are partially exempt

Employees on payroll Employees not on payroll who are supervised on a day-to-day basis Exclude self-employed and partners Temporary help agencies should not record the cases experienced by temp workers who are supervised by the using firm

Keep a separate OSHA Form 300 for each establishment that is expected to be in operation for more than a year May keep one OSHA Form 300 for all short- term establishments Each employee must be linked with one establishment

Easily accessible information in a condensed format A thumbnail sketch of the things causing harm to employees Helps employers “recognize hazards causing or likely to cause harm” Helps inspectors focus their audits

OSHA's Form 300, the Log of Work-Related Injuries and Illnesses (replaced the OSHA 200) – information on injuries and illnesses in a condensed format The 301 form (replaced the OSHA 101) – detailed record of each case recorded on the 300 form Form 300A is the summary of work-related injury and illness cases. This is the form that is posted every year for the previous year’s log

The OSHA 301 “Injury and Illness Incident Record” provides detailed information about: o the affected worker, o the injury or illness, o the workplace factors associated with the accident, o a brief description of how the injury or illness occurred. Equivalent workers' compensation “First Report” form or internal forms are okay, so long as all of the same information is included.

Summarizes entries from the Form 300 Log Post February 1 – April 30 of the following year Gives employees an overview of the actual hazards in their workplace Contains totals for each column from the Form 300, plus the average number of employees and total hours worked Certification of the data by a company executive is required. NOTE: By law, the 300A must be signed by an “executive” of the company – Not a designee.

Record every fatality, injury or illness that meets these criteria: o Work-related, o A new case, o Meets one of the general or specific recording criteria found in the regulation. The same requirements now apply to both injuries and illnesses.

Aggravation of a Pre-existing condition is “work related” and recordable when a work event or exposure causes one of the following (Presuming that this outcome would not have occurred without the work event or exposure): o death o loss of consciousness o a day or days away from work, restricted work or job transfer o medical treatment or a change in the course of medical treatment.

An injury or illness that occurs while an employee is on travel status is work-related if it occurred while the employee was engaged in work activities in the interest of the employer Home away from home Detour for personal reasons is not work-related

Injuries and illnesses that occur while an employee is working at home are work-related if they: o occur while the employee is performing work for pay or compensation in the home, and o they are directly related to the performance of work rather than the general home environment

A case is new if: o The employee has not previously experienced a recordable injury or illness of the same type that affects the same part of the body; or o The employee previously experienced a recordable injury or illness of the same type that affects the same part of the body, but had recovered completely and an event or exposure in the work environment caused the signs and symptoms to reappear o If there is a medical opinion regarding resolution of a case, the employer must follow that opinion

Cases occurring on the work premises are presumed to be work-related except when they involve: o Eating, drinking or preparing food or drink o Common colds and flu o Voluntary participation in wellness program, medical, fitness, or recreational activity o Mental illness (unless employee voluntarily provides an opinion from a licensed health care professional stating condition is work related) o Employee is at work as a member of the general public rather than as an employee. o Symptoms surface at work but result solely from a non-work-related event or exposure. o Doing personal tasks at work outside normal work hours. o Grooming, self-medication, or intentionally self-inflicted. o A motor vehicle accident on a company parking lot or company access road while commuting to or from work

Death Days away from work Restricted work or job transfer Medical treatment beyond first aid Loss of consciousness Diagnosis by a PLHCP as a significant injury or illness

Record if the case involves one or more days away from work Check the box for days away cases and count the number of days Do not include the day of injury/illness

Restricted work activity occurs when: o An employee is kept from performing one or more routine functions (work activities the employee regularly performs at least once per week) of his or her job; or o An employee is kept from working a full workday; or o A PLHCP recommends either of the above

Job Transfer o An injured or ill employee is assigned to a job other than his or her regular job for part of the day o A case is recordable if the injured or ill employee performs his or her routine job duties for part of a day and is assigned to another job for the rest of the day

Medical treatment is the management and care of a patient to combat disease or disorder It does not include: o Visits to a PLHCP solely for observation or counseling o Diagnostic procedures o First aid

Using nonprescription medication at nonprescription strength Tetanus immunizations Cleaning, flushing, or soaking surface wounds Wound coverings, butterfly bandages, Steri-Strips Hot or cold therapy Non-rigid means of support Temporary immobilization device used to transport accident victims

Drilling of fingernail or toenail, draining fluid from blister Eye patches Removing foreign bodies from eye using irrigation or cotton swab Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means Finger guards Massages Drinking fluids for relief of heat stress

All work-related cases involving loss of consciousness must be recorded

Includes all punctures, cuts and lacerations caused by needles or other sharp objects contaminated (or presumed contaminated) with blood or OPIM Such injuries may later cause diseases like AIDS, hepatitis B and hepatitis C and must be monitored Does not require the recording of all cuts and punctures. (e.g.: A cut made by a knife or other sharp object not contaminated by blood or OPIM would not be recordable if only first aid was required)

CURRENT RULE:OLD RULE: 10 dB loss from original or revised baseline in either ear ONLY when accompanied by an overall 25 dB shift from audiometric zero (normal hearing) 25 dB loss from original or revised baseline in either ear Both based upon average of audiometric results at 2000, 3000 & 4000 Hz Both allow age adjustments according to the Hearing Conservation Standard

MSD cases like carpal tunnel syndrome are recordable on the 300 log if they meet general recording criteria Employer retains flexibility to determine whether an event or exposure in the work environment caused or contributed to the MSD

Must record cases when there is a known exposure to tuberculosis and an employee develops a tuberculosis infection. Must record a case on the OSHA 300 Log whenever an employee is medically removed under the medical surveillance requirements of any OSHA standard. Must be recorded as a case involving days away from work or as a case involving restricted work activity, depending upon the removal requirements

Count “days away” or “days restricted or transferred” for every day after the date of incident or onset (the day of injury or illness is not counted) Count all calendar days, including weekends, holidays, shutdowns and vacations There is a limit on how long employers are required to track cases. Days away or days of restriction do not have to be counted beyond 180 days, total for both categories

Employers must inform employees of how to report an injury or illness. Employers are prohibited from discriminating against employees for reporting injuries and illnesses. Employees may access the 301 forms for their own cases Employee representatives now have a right to view the right-hand column of the OSHA 301 Employees, former employees, and employee representatives (union, attorney, physician, etc.) have a right to view a copy of the Log

Employers must withhold the employee's name from the OSHA log for "privacy concern cases" A separate list of case numbers and employee names must be provided to OSHA upon request Privacy concern cases include: o Intimate body part or reproductive system o Resulting from a sexual assault o Mental illness o Communicable diseases (HIV, hepatitis, tuberculosis) o Contaminated Needlestick and sharps injuries o Other merited employee requests

The Form 300A must be certified at the end of each year It must be posted from February 1 until April 30 of the year following A company executive must certify the accuracy of the data

Must report fatalities and hospitalizations of three of more employees to OSHA within 8 hours. The report must be made to the OSHA area office or the toll free number (OSHA). Clarifications in the rule relating to reporting: o Employers must report fatal heart attacks that occur at work o Employers do not have to report motor vehicle accidents that occur in a public street o Employers do not have to report public transport accidents Even when accidents are not reportable, they are recordable if they meet OSHA's recordability criteria.

Days Away From Work Days of Restricted Work Activity Job Transfer Formula: o Number of entries in Column H x 200,000/Number of hrs worked by all employees = DART incidence rate

Incidence rate for all recordable cases of injuries and illnesses Formula: o Total number of injuries & illnesses x 200,000/Number or hrs worked by all employees = Total recordable case rate

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