1. Department of Defense Voluntary Protection Programs Center of Excellence Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense Department of Defense Voluntary Protection Programs Center of Excellence VPPPA 28 th Annual National Conference The Obstacles of OSHA Recordkeeping “Getting It Right in the DoD” Bill Leipprandt Principal Safety Professional August 21, 2012 1

2. Department of Defense Voluntary Protection Programs Center of Excellence Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense Welcome

3. Objectives 3 Review importance of OSHA recordkeeping Discuss common DoD compliance issues Review recordkeeping issues observed at sites Provide tips to improve recordkeeping skills

4. Housekeeping Review safety evacuation information Request attendees to shut off electronic devices 4

5. Department of Defense Voluntary Protection Programs Center of Excellence Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense An Introduction to OSHA Recordkeeping

6. The Importance of Recordkeeping Means to collect, record, and track work-related deaths, injuries, and illnesses Basis for trend analysis Allows for calculation of injury and illness rates (DART, TCIR) Requirement to participate in VPP recognition 6

7. Trend Analysis 1960.66(c) – Identify unsafe and unhealthful working conditions and establish program priorities VPP – Develop a Trend Analysis Program to analyze safety and health trends 7

8. Department of Defense Voluntary Protection Programs Center of Excellence Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense Common Recordkeeping Issues in the DoD

9. Certification of OSHA logs 9 DoD Compliance Issues OSHADoD 1904.321960.67(a)-(c) Highest ranking official Senior Establishment Management Official Head of the Agency (who senior official works for) Any management official in direct chain of command between the two

10. Following OSHA regulations or DoD requirements 10 DoD Compliance Issues OSHADoD 29 CFR 19041960.66(b) Under and over reporting is a violation Directs to follow OSHA’s recordkeeping requirements set forth in 29 CFR 1904 29 CFR 1904.32(b)(6) Must post OSHA 300A summary from February 1–April 30

11. Commonly seen “red flags” –Minor musculoskeletal discomfort issues being recorded –High noise areas and employees receiving compensation for hearing loss with no recorded standard threshold shifts (STSs) –Not including work restriction cases in the DART –Miscalculating injuries and illnesses recorded on the OSHA logs 11 DoD Compliance Issues

12. Observations Multiple groups of personnel with different chains of command are involved Communication is flawed among the groups Injury/illness databases cannot always pull the correct data for OSHA logs Obtaining OSHA logs for a defined site is sometimes difficult 12

13. Observations Many confuse differences between incidents that are: –Military reportable – Any incident that could have (near-miss, first aid) or did result in an injury or illness –Compensation worthy – Replaces wages and pays for medical expenses for those injured at work –OSHA recordable – Determined according to specific guidelines set forth in 29 CFR 1904 OSHA recordkeeping rules are not always well understood 13

14. Department of Defense Voluntary Protection Programs Center of Excellence Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense The Prescription to Your Success

15. Prescription for Success 15 Why do these recordkeeping issues continue? “Prescription without diagnosis is malpractice, whether in medicine or management.” - Unknown Author Why do these recordkeeping issues continue? “Prescription without diagnosis is malpractice, whether in medicine or management.” - Unknown Author

16. Prescription for Success Think about… –What can you control? –What changes can you institute for improvement? –What recommendations can you communicate up the chain of command to improve recordkeeping compliance? –What unconfirmed information do you need answered before determining if a case should be recordable? 16

17. Department of Defense Voluntary Protection Programs Center of Excellence Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense Conclusion

18. Read through OSHA Recordkeeping regulations and understand contents Establish a good relationship with record keeper Understand differences between military reportable, compensation worthy, and OSHA recordable Investigate all incidents to gather needed information and determine if they are OSHA recordable 18

19. Conclusion Improve communication among groups of personnel that work to compile data Double check any injury and illness data pulled from a database Keep separate list of non-recordable cases Write legibly when maintaining written logs Use buddy system to check information entered into OSHA logs Be sure the record keeper has been trained 19

20. Useful Resources OSHA Recordkeeping Handbook –http://www.osha.gov/Publications/recordkeeping /OSHA_3245_REVISED.pdfhttp://www.osha.gov/Publications/recordkeeping /OSHA_3245_REVISED.pdf OSHA Recordkeeping Page –http://www.osha.gov/recordkeeping/http://www.osha.gov/recordkeeping/ OSHA Recordkeeping Standard –http://www.osha.gov/pls/oshaweb/owasrch.sear ch_form?p_doc_type=STANDARDS&p_toc_lev el=1&p_keyvalue=1904http://www.osha.gov/pls/oshaweb/owasrch.sear ch_form?p_doc_type=STANDARDS&p_toc_lev el=1&p_keyvalue=1904 20

21. Department of Defense Voluntary Protection Programs Center of Excellence Development, Validation, Implementation and Enhancement for a Voluntary Protection Programs Center of Excellence (VPP CX) Capability for the Department of Defense QUESTIONS?? Visit our Booth! Visit the DoD VPP CX Booth to find out more information about our services and products and how we can help you!