Recordkeeping & Reporting Joe Margetiak Compliance Officer Toledo Area Office June 2015

Recordkeeping Highlights Changes to 29 CFR 1904 Effective January 1, 2015

NAICS vs. SIC Codes Need to use NAICS from now on – North American Industry Classification System (NAICS) – Standard Industry Classification (SIC) On-line guide available OSHA 300A forms need NAICS code

Partially Exempt from Recordkeeping Do not have to keep OSHA 300 and OSHA 300A forms Employers who have 10 or fewer employees at all times during the previous calendar year List of industries with injury rate 75% or less of 3-year average

Industry Examples Florists Shoe Store Sporting Goods Stores Colleges Restaurants Car Dealers Doctors

Injury Reporting Requirements Changes to 29 CFR 1904 Effective January 1, 2015 Published September 18, 2014 (proposed rule published June 22, 2011)

Previous Reporting Requirements Work-related fatality Heart attack fatality Hospitalization of 3 or more employees Injuries involving a mechanical power press – (g)(1): The employer shall report, within 30 days of the occurrence, all point-of-operation injuries to operators or other employees

Notification requirements as of January 1, 2015 Work-related fatality Work-related in-patient hospitalization Heart Attack Work-related amputation Work-related injury resulting in the loss of an eye Mechanical power press point-of-operation injury

Fatality Report within 8 hours of when you find out If the fatality occurs within 30 days of the work-related incident Does not include traffic accidents (except construction zones) & public transportation Includes heart attack

Hospitalization Report within 24 hours One or more employees Admitted for treatment If hospitalization occurs with 24 hours of incident Includes heart attack Observation or testing does not count Does not include traffic accidents (except construction zones) & public transportation

Heart Attack Heart attack vs. sudden cardiac arrest Not always instantaneous – symptoms may occur over a period of time* May be caused by some work activity that occurred hours earlier* Sudden cardiac arrest, such as from an electrical shock, may appear to be a heart attack* May or may not be investigated by OSHA Evaluated on a case-by-case basis * Mayo Clinic: Disease and Conditions Heart Attack

Amputation* Report within 24 hours Does not include traffic accidents (except construction zones) & public transportation If amputation occurs with 24 hours of incident Definition of amputation does not include: – avulsion, enucleations (loss of eye), deglovings, scalpings, severed ears, broken/chipped teeth * as defined in BLS OIIC 2010 manual

Loss of an eye Report within 24 hours If loss occurs with 24 hours of incident Does not include traffic accidents (except construction zones) & public transportation (no reference to blindness)

Reporting Can not leave a message on an OSHA answering machine/voice mail; no ; no fax Options: – Electronic reporting (not yet) – Call OSHA hotline – Call local office (8:00 - 4:30)