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2 OSHA Recordkeeping National Emphasis Program Steve Ohman, Manager Spectrum Health Occupational & Employee Health Services January 25, 2011 Employer Advisory Council [Master name: Solid Color Background]

3 History & Background – Spectrum Health Who We Are We are the largest employer in West Michigan with 16,000 staff members, 1,500 physicians, and 2,350 volunteers. Our service area covers a population of 9.5 million. In FY09, we had a net system revenue of $2.7 billion. We have three businesses: Priority Health, Spectrum Health Medical Group and Spectrum Health Hospital Group. [Master: Solid Color Background]

History & Background – Spectrum Health Priority Health Priority Health Priority Health is a nationally recognized health benefits company that provides half a million Michigan residents with access to affordable and excellent health care. Priority Health has offices in Grand Rapids, Farmington Hills, Holland, Jackson, Kalamazoo, Saginaw and Traverse City. Spectrum Health Medical Group Spectrum Health Medical Group We established the Spectrum Health Medical Group to recognize the critical role physicians play as an equal partner with our hospitals and health plan. It was established to bring together our employed physicians into one group, in the form of a not-for-profit corporation. The group is supported by a common vision, infrastructure, systems and processes.

History & Background – Spectrum Health Spectrum Health Hospital Group Spectrum Health Hospital Group The Spectrum Health Hospital Group reflects the full range of health care services provided in our inpatient, outpatient and continuing care settings. It includes all of our hospitals, outpatient facilities, and continuing care and long-term care facilities within a geographically designated 13-county referral area. In FY09, Spectrum Health Hospital Group had 60,500 acute admissions and served hundreds of thousands of patients at its more than 140 service sites.

History & Background – Spectrum Health Hospitals Spectrum Health Blodgett HospitalSpectrum Health Blodgett Hospital, East Grand Rapids Spectrum Health Kelsey HospitalSpectrum Health Kelsey Hospital, Lakeview Spectrum Health Medical Center, Grand Rapids ■ Butterworth Hospital Butterworth Hospital ■ Fred and Lena Meijer Heart Center Fred and Lena Meijer Heart Center ■ Helen DeVos Children’s Hospital Helen DeVos Children’s Hospital ■ Lemmen-Holton Cancer Pavilion Lemmen-Holton Cancer Pavilion Spectrum Health Reed City HospitalSpectrum Health Reed City Hospital, Reed City Spectrum Health Special Care HospitalSpectrum Health Special Care Hospital, Grand Rapids Spectrum Health United HospitalSpectrum Health United Hospital, Greenville

History & Background – Spectrum Health Outpatient Care Ambulatory Surgery Centers Laboratory Occupational Health Radiology Rehabilitation Sleep Disorders Urgent Care Continuing Care Continuing Care With 600 beds and 1,200 patients a day, Spectrum Health Continuing Care is the largest provider of integrated post-acute care in West Michigan. It includes: Spectrum Health Hospice Spectrum Health Infusion Pharmacy Services Spectrum Health Neuro Rehabilitation Services Spectrum Health Rehab & Nursing Centers Spectrum Health Special Care Hospital Spectrum Health Visiting Nurse Association 7

OSHA’s New Enforcement Emphasis Recordkeeping National Emphasis Program (NEP) Launched 10/09 to “assess” accuracy of injury recordkeeping Obama admin increased OSHA’s size and enforcement actions 1 year later – 200 inspections launched with 70% violations found Targeted industries: Mfg; Large worksites & high injury rates $100,000+ fines tripled in last year Overall emphasis = increased fines and focus on recordkeeping issues MSU Study found 68% of recordable injuries not documented 8

OSHA’s New Enforcement Emphasis National Emphasis Program (NEP) Launched 10/09 to “assess” accuracy of injury recordkeeping Obama admin increased OSHA’s size and enforcement actions 1 year later – 200 inspections launched with 70% violations found Targeted industries: Mfg; Large worksites & high injury rates $100,000+ fines tripled in last year Overall emphasis = increased fines and focus on recordkeeping issues Severe Violator Enforcement Program (pub 6/18/10) MSU Study found 68% of recordable injuries not documented 9

OSHA’s New Enforcement Emphasis RK National Emphasis Program (NEP) Components 1. Records review (logs; WC records; personnel records, etc. Medical Access Order needed) 2. Interviews (staff; mgmt; healthcare providers) 3. Inspections 10

OSHA’s New Enforcement Emphasis Recommendations OSHA Logs are up to date (medical>restricted>LT) Cross check logs against other injury/illness records Review recordkeeping standards and interpretations Get the facts early and often (OSHA’s 7 day rule) Review injury/illness reporting disincentives 11

OSHA’s New Enforcement Emphasis Pressures (from many directions) OSHA numbers are used for performance indicators Incentives & financial bonuses sometimes tied to rates – OSHA target Encouraging not reporting injuries (= increased severity) Hard to understand a case being recordable even though no-fault of management &/or employee & unforeseen Facts and good medical judgment are best allies Use leading indicators vs. trailing indicators (% of staff trained; reductions in number of noisy machines; employee surveys, etc.) 12

OSHA’s New Enforcement Emphasis (MI)OSHA Log Recordkeeping Each employer is required to keep records of work-related fatalities, injuries and illnesses that meet one or more of the general recording criteria, including: Death, Days away from work, Restricted work, Transfer to another job, Medical treatment beyond first aid, Loss of consciousness, or A significant injury/illness diagnosed by a physician or other licensed health care professional. 13

OSHA’s New Enforcement Emphasis (MI)OSHA Log Recordkeeping A case is considered work-related if an event or exposure in the work environment either caused or contributed to the resulting condition. A case is considered work-related if an event or exposure in the work environment significantly aggravated a pre-existing injury or illness. (Significant aggravation is defined in Rule 1110(d)(i-iv.) First Aid vs. Recordable (see handout) 14

OSHA’s New Enforcement Emphasis Recordkeeping –What’s Not Recordable?? Injury/illness did not result from event/exposure at work 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. 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. 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). For example, if the employee is injured by choking on a sandwich while in the employer’s establishment, the case would not be considered work-related. 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. 15

OSHA’s New Enforcement Emphasis Recordkeeping –What’s Not Recordable?? 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. The injury or illness is solely the result of personal grooming, self medication for a non- work-related condition, or is intentionally self-inflicted. 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. 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 with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related. The illness is the common cold or flu (contagious diseases such as tuberculosis, brucellosis, hepatitis A, or plague are considered work-related if the employee is infected at work).

OSHA’s New Enforcement Emphasis NEP Core Principles (or How to stay off the list!) 1. OSHA will err on the side of recordability 2. Establish regular meetings to discuss determinations and log entries 3. Don’t make a premature recordability determination/entry 4. Establish procedure to review and update logs at least every three months 5. Compare OSHA logs with WC claim data 6. Follow OSHA’s (40+) letters of interpretation on record keeping 7. Review safety incentive programs 8. Process and communications on how to report an injury 9. Do more than just record - use the data

18 Thank You!

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