1. OSHA Recordkeeping
“Welcome to OSHA Recordkeeping. The purpose of this presentation is to provide with information how to keep accurate records of workplace accidents and injuries per OSHA’s requirements. This presentation will provide information to help you comply with OSHA’s 1904 recordkeeping standard. The records can also be used for other purposes, such as tracking injuries and illnesses or identifying trends of accidents in the workplace.”

2. Does This Standard Apply to You? (Partially Exempt Industries)
An employer who had no more than 10 employees at any time
Hardware stores
Meat & fish markets
Eating & drinking places
Liquor stores
Insurance carriers
Apparel & Accessory Stores
New and Used Car Dealers
Gasoline service stations
Real estate agents
Photographic studios
Reupholster & furniture repair
Radio, t.v. & computer stores
Offices & clinics of MD’s, Dentists, other Health practitioners
Medical & dental labs
Legal services
Educational services
Child day care services
Museums & art galleries
Motion picture
Producers, orchestras, entertainers
Bowling centers
Advertising services
Credit reporting & collection services
Beauty & barber shops
“Some employers, based on their type of establishment, are exempt from recordkeeping. Several of these industries are listed. Please refer to the Non-Mandatory Appendix A to Subpart B for a complete list of industries. Remember, even if you are a partially exempt industry, OSHA, the Bureau of Labor Statistics (BLS), or any state agency operating under OSHA’s or the BLS’ authority may still request information.”

3. State Programs
Check your own state program for recordkeeping requirements.
“If you live in a state that is covered under a state program, and not Federal OSHA, please refer to your own state program for recordkeeping requirements.”

4. What are the Recordkeeping & Reporting Requirements?
If you are covered under Federal OSHA you must keep these records or report the following:
OSHA Form 300 “Log”
OSHA Form 300A “Summary”
OSHA Form 301 or equivalent
Fatalities
Hospitalization of 3 or more employees
All fatal heart attacks that occur in the work environment
Please check your state program if applicable.
(Read slide). When reading “if you are covered under Federal OSHA” add “you are required to maintain the OSHA Form 300 Log, the OSHA Form 300A Summary and the Form You are also required to report within 8 hours any fatalities or if three or more employees are hospitalized as a result of a work-related incident. Again, please check your individual state plan for their recordkeeping and reporting requirements.”

5. What’s Recordable? Fatality. Loss of consciousness.
Days away from work.
Restricted or light duty work as ordered by a health provider.
Any work injury or illness that is significant.
Medical treatment (see next slide).
Prescription medication ordered (even if it is over the counter medication given at prescription levels).
“What makes an injury or illness recordable? Any time a work-related incident results from the following…” (read slide now – when read “medical treatment” explain there will be more information about this on the following slide). “The incident has to occur in the course of performing work duties. One example that may help to clarify this is when incidents happen in facility parking lots. In one situation, an employee falls in a parking lot while coming into the facility to start their shift and subsequently needs medical treatment. This would not be recordable because walking in the parking lot is not part of their job duties. In contrast, a maintenance person who has been asked to salt a parking lot as part of their job, falls in the parking lot and then requires subsequent light duty work. This would be a recordable accident since the maintenance employee fell in the parking lot performing assigned job duties (and subsequently required light duty work). As for claim compensability please consult your insurance company.”

6. Medical Treatment
Diagnostic test with positive findings (i.e., positive x-ray, CT scan).
Usually includes admission to a hospital.
Sutures are given.
Therapy is given or prescribed.
Using a derma-bond to close a wound.
Rigid supports, splints
“What does OSHA define as medical treatment?” (read slide). “Remember if any medical treatment is given, the injury or illness must be recorded on the log.”

7. Other Recordable Criteria
Needle stick injuries or cut from sharp object contaminated with blood or OPIM’s (other potentially infectious materials).
A situation where an employee has to be medically removed under OSHA’s health standards.
TB per a “+” skin test, physician diagnosis or exposure to known case of active TB.
Employee audiogram reveals standard threshold shift in one or both ears and total hearing level is 25 dB or more above audiometric zero.
Note: Other infectious diseases:
To be recordable, it must fit recordable criteria.
Exposure alone is not recordable; exposure must cause a “+” test result.
Follow-up on cases to see if exposure caused “+” test outcomes.
“The following conditions are also recordable if work-related”
(read slide – after finishing the first bullet point about needle stick injuries add “needle stick injuries are entered on the log as an injury but you do not put the employee’s name on the log for privacy reasons”
(“TB” is tuberculosis; “dB” means decibels).

8. What’s Not Recordable
Visit to a provider solely for observation or evaluation.
Diagnostic tests with negative findings.
First aid is given (see next slide).
Non-prescription or over-the-counter medications are given.
Accident/illness occurred outside the course of work.
“The following items would not be recordable” (read slide – when read about first aid explain that there will be more information about this on the next slide).
“Remember, however, that at any time an injury or illness could become recordable based on the course of treatment. For example, first aid may be initially given at the time of the injury. At this time, the accident would not be recordable. However, the employee then may go to a clinic and undergoes an x-ray which reveals positive findings for a broken bone. This case then does become a recordable injury from the subsequent testing done.”

9. First Aid Tetanus shot Cleaning, flushing, soaking surface wound
Wound coverings (butterfly, bandage, steri-strips
Hot/cold therapy
Non-rigid support (wrap)
Temp. immobilization device used to transport employee
Drilling finger/toe nail
Draining blister
Eye patch
Remove foreign body from eye with swab, irrigation
Remove foreign body from skin with tweezers, swab, irrigation etc.
Finger guard
Massage
Drink fluids for heat stress relief
Using type liquid bandage to cover a wound
“The following are considered first aid acts and therefore not recordable” (read slide).

10. OSHA’s Form 300 “Log” How to Complete
First complete establishment’s name & location in the upper right of the log.
Column A (case number). This is usually done in numeric order.
Column B (employee name).
“Each employer must maintain a log and summary of injuries and illnesses in each establishment. The 300 log is used to classify work-related injuries or illnesses and to note the extent and severity of each case.
(read slide – for the 3rd bullet point “column B” say “There are certain situations where the employee’s name is not put on the log for privacy reasons. We will cover this information next. For these situations you will enter “privacy case” in column B instead of the employee’s name.”

11. Do Not Put Name on Log When… (Column B)
Injury/illness to reproductive part or intimate body part.
Injury/illness from sexual assault.
Mental illness.
Case of HIV, TB or hepatitis.
Needle stick injury or cut from sharp object that is contaminated with blood or OPIM’s.
If employee independently & voluntarily requests their name not be on the log.
Instead enter “privacy case” where the name would usually go on the 300 Log.
You must then keep a separate, confidential list of the case numbers & employees’ names.
“Do not put an employee’s name on the 300 Log when…” (read slide).

12. OSHA’s Form 300 “Log” How to Complete
Column C (job title).
Column D (date of injury or illness onset).
Column E (where the incident occurred).
“Then complete column the following three columns…” (Read slide).

13. OSHA’s Form 300 “Log” How to Complete
Column F (describe injury or illness).
Classify the case (columns G, H, I, J):
Choose only one of these categories
Record the most serious outcome of each incident:
For example, if the employee missed 2 weeks of work per physician’s orders and then was on light duty for 1 week, record this as “days away from work” as this is more serious than light duty for one week.
(Read slide). For “column F” say “it is important to be as specific as possible for column F. You can use multiple lines on the form if you need to.”

14. OSHA’s Form 300 “Log” How to Complete
Next complete how many days the employee was away from work or did work but with a job transfer or restriction (columns K, L):
Count calendar days, not only the days the worker was scheduled to work.
Do not count the date of injury.
Complete both columns if applicable.
(Read slide).

15. OSHA’s Form 300 “Log” How To Complete
Column M 1-6 (check whether the incident was an injury or choose which illness).
Make sure to put totals at the bottom of all columns when the page is full and/or at the end of the calendar year.
First read “Then complete column M 1-6…” (then read rest of slide).

16. OSHA’s Form 300 “Log” Classifying Injuries vs. Illnesses
Cut
Puncture
Laceration
Abrasion
Fracture
Bruise
Contusion
Chipped tooth
Amputation
Insect bite
Electrocution
Radiation burn
Sprains/strains (from slip,trip, fall
Illnesses:
Skin disease or disorder
Respiratory conditions
Poisoning
Hearing Loss
Other:
Effects environmental heat or cold
Decompression sickness
Ionizing and nonionizing radiation
Anthrax
BBP disease
Tumors
Brucellosis
Histoplasmosis
“How do you know whether to classify an incident as an injury or as an illness? This list may help you to determine how to record the incident.” (read left column first, then list under right column – “BBP” is bloodborne pathogens”

17. OSHA’s Form 300 “Log” Other Notes
Each recordable case must be recorded within 7 calendar days of receiving the information.
If the outcome changes after the entry:
Draw a line through the entry OR
Delete the entry OR
White-out the entry
Re-record the incident where it belongs
Stop counting days when it exceeds more than 180 days (enter “180” or “180+”).
Can include days away from work, restricted/alternate work days, or a combination of both.
(Read slide)

18. OSHA’s Form 300 “Log” Other Notes
If your company has multiple sites keep separate records for each physical location (that is in operation 1 year or longer).
Cases that carryover to the next year:
Example: Employee is hurt on December 29th and is away from work until January 10th.
You only need to record this case once (the year it occurred).
If the employee is still away when summary is prepared (before Feb. 1st) either count the number of days employee was away or estimate total days away that are expected.
Update the Log entry later when the actual number of days is known (or the case reaches the 180-day cap).
Read slide.

19. OSHA’s Form 300A Summary
Transfer totals of columns G – M from the 300 Log onto the corresponding spaces of the 300A Summary.
Make sure to include all employees that were:
Full-time
Part-time
Temporary
Seasonal
Salaried
Hourly
“At the end of the calendar year, You will now transfer information from the 300 Log to the 300A Summary form. (Read slide).
“Now you must complete and post the OSHA Form 300A Summary.

20. OSHA’s Form 300A Summary Complete Establishment section.
Complete Employment section:
Please refer to the Summary worksheet if you need assistance completing:
average number of employees
total hours worked
Complete the signature section:
Ensure a top company executive signs the Summary.
“Next complete the Establishment section, such as the facility’s address. Include a brief description of the industry. For example a description could be – manufacturer of hand tools. Then complete your Standard Industrial Classification or SIC code, if known. OR fill in your North American Industrial Classification (NAICS) code, if known. Under the Employment section use available record information to help complete the average number of employees and total hours worked section. If this information is not available, OSHA provides a worksheet for the Summary to help you complete this area. Once completed and reviewed, the Summary must be signed-off by a top company executive.

21. OSHA’s Form 300A Summary - Posting
The 300A Summary is posted Feb. 1 through April 30th of the next calendar year (example: the summary for 2007 is posted Feb. 1 through April 30th 2008).
You do not post the 300 Log.
Post the 300A Summary in a visible location.
(Read slide).
When you read “you do not post the 300 Log – add “ only post the 300A Summary form.”

22. Recordkeeping for Contracted Employees
If you have contracted employees:
Injuries and illnesses are counted on the 300 log and summary
Include their work hours in the summary
Exception: if the contracted company has their own management on-site you do not need to count their injuries/ illnesses or work hours:
Example: Company A has hired Ajax Cleaning to do housekeeping in the facility. Ajax has their own supervisor on-site. Ajax then is responsible for their own recordkeeping.
(Read slide).

23. For 300 & 300A Forms
Even if there were no cases for a calendar year, there still must be a Form 300 and 300A completed.
Put “zero” in the columns if this is the outcome – don’t leave columns blank.
(Read slide).

24. OSHA’s Form 301 Incident Report
Each recordable case must be recorded within 7 calendar days of receiving the information.
Some state’s Worker’s Compensation, insurance or similar reports may be acceptable substitutes (example: IL Form 45).
Substitute forms must contain all the information as Form 301 requests.
“The 301 form or an equivalent form, must be completed as well. Similar to the OSHA Log, the 301 must be completed also within 7 calendar days.” (read rest of slide).

25. How Long Do You Keep Records?
You must keep the current year’s records (300, 300A, 301) plus the previous five (5) years of records.
Make sure records are readily accessible and that more than one person has access to the records.
Records do not have to be sent to OSHA unless OSHA requests.
Present employees, past employees and their representatives are allowed to view the Form 300 “Log”.
Forms can be kept on the computer as long as they can be produced when needed.
(Read slide).
For second bullet point add “it is important that should OSHA or any other allowable agency ask for your records should the primary record keeper is absent, the records can still be readily located and produced.”

26. Common Situations NOT Recordable
Employee was present in the work environment as a member of the general public and not as an employee.
Injury/illness signs or symptoms appear at work but resulted solely from outside work.
Incident occurred from voluntary participation in wellness program, fitness, medical, or recreational activities.
Eating, drinking, or food prep for personal consumption even if bought on employer’s premises or brought in.
Occurs solely from employee doing personal tasks at the establishment or outside working hours.
Incident occurred from result of personal grooming, self-medication.
There is a MVA which occurs in company parking lot or access road when employee is commuting.
Common cold or flu.
Mental illness (unless HCP states is work-related).
“It may be difficult to assess if an incident is recordable. These are common situations where typically the injury or illness outcome would NOT be recorded. These include:…” (Read slide).
After read “eating, drinking…” bullet point, add “however, if the employee is made ill by ingesting food contaminated by workplace contaminants (such as lead) or gets food poisoning from food supplied by the employer, the case would be considered work-related (recordable)”
For “MVA” read “motor vehicle accident”
For “common cold or flu…” add “contagious diseases, however, such as TB and hepatitis are considered work-related (and therefore recordable) if the employee is infected at work”.
For “HCP” read “health care provider”

27. How About Travel? Is considered work-related if:
An injury or illness occurs while an employee is on travel status, or if it occurs while the employee was engaged in work activities.
If an employee detours for personal reasons than the incident is not work-related.
“How about travel for work? If an incident occurs when traveling for work, is it recordable? (Read slide).

28. How About Working at Home?
Injuries & illnesses that occur while an employee is working at home are work-related if:
They occur while the employee is performing work for pay or compensation in the home and
Are directly related to the performance of work rather than the general home environment.
(Read slide).

29. Other Required Reporting
You must report any of the following to OSHA within 8 hours:
Fatality of any employee due to work-related incident.
Any in-patient hospitalization of 3 or more employees.
Report by phone or in person to an Area Office of OSHA or USDOL.
Report any fatal heart attack that occurred in the work environment.
“There are other reporting requirements by OSHA.”
(Read the slide now – please add after reading the first bullet point “if the employer does not learn of a reportable incident at the time it occurs, the employer must make the report within 8 hours of the time the incident is reported”).
“Ensure these items are properly recorded on your OSHA 300 log, 301 and summary form.”
“You must report any fatal heart attack to OSHA so they can determine work-relatedness of the fatality. You must report the fatal heart attack whether it occurred at work or at home.”

30. Other Required Reporting – Sharps Log
OSHA (h)(5)(i) requires employers to maintain a sharps injury log for percutaneous injuries from contaminated sharps.
The log must:
Protect the confidentiality of the injured employee
Identify the type and brand of the device involved
Identify the department or work area where the incident occurred
Provide an explanation how the incident occurred
Be maintained like the 300 log (have the current log plus previous 5 years’ logs).
Enter the case on the OSHA 300 log as an injury but with no employee name (use “privacy case”).
Read slide

31. References OSHA 1910.1904 standard. www.OSHA.gov
“For additional help or resources you can refer to the 1904 OSHA standard, OSHA’s web-site or local office or contact your state agency if applicable.”