OSHA Recordkeeping OSHA 29 CFR 1904 PRESENTED BY

OSHA Recordkeeping ( OSHA 29 CFR 1904 ) PRESENTED BY SHEAKLEY UNISERVICE, INC. SHEAKLEY’S HEALTH AND SAFETY SERVICES

Objectives / Outcomes • Discuss why injury & illness records are important • Determine if standard applies to your place of employment • Review standard revisions on severe injury reporting requirements • Explain the most recent addition to the rule for online reporting • Differentiate between recordable and non-recordable cases • Review OSHA Recordkeeping requirements and forms: 300, 301, and 300 A • Introduce administrative solutions

Why keep injury-illness records? • Captures data on how people get hurt • Helps identify problem areas / trends • Helps prevent future injury or illness • More effective safety program • Increase employee safety awareness • It may be a Federal requirement within your facility • 200, 000 BLS surveys are mailed each year

Vs. U. S. Department of Labor Occupational Safety and Health Administration • A common misconception is that if it is a workers’ comp injury then it is also an OSHA recordable injury • OSHA Recordkeeping and the BWC processes are independent of each other. • A rule of thumb is: – All OSHA recordable injuries are workers’ comp claims – Not all workers’ comp injuries are OSHA recordable

Key Elements • Employers with 10 or fewer employees (includes temporary employees) are exempt from recordkeeping requirements • Currently all employers must report fatalities in 8 hours to OSHA. As of January 2015, in addition to notifying OSHA of fatalities, you must also call them within 24 hours of finding out about them: • • All work-related amputations • All work-related losses of an eye • All work-related in-patient hospitalizations of one or more employees To report an incident: • Call 1 -800 -321 -OSHA • Call your nearest OSHA area office • Visit http: //www. osha. gov/report_online

When must I contact OSHA? Prior to January 2015, employers reported fatalities in 8 hours to OSHA. In addition to notifying OSHA of fatalities, you now must also call them within 24 hours of the below occurrences: All work-related amputations • Loss of a limb or other external body part • Includes: A part, such as a limb or appendage, that has been severed, cut off, amputated (completely or partially); fingertip amputations with or without bone loss; medical amputations from irreparable damage All work-related losses of an eye • Loss of entire eyeball • Does not relate to vision All work-related in-patient hospitalizations of one or more employees • Defined as a formal admission to the inpatient services of a hospital or clinic for care or treatment • Inpatient admission for diagnostic testing or observation does not apply

News Just In … Prior to OSHA’s severe injury/ illness reporting rule has come to confirm: All work-related amputations • 2, 644 amputations were reported • Primarily manufacturing All work-related losses of an eye • No data statistics calculated All work-related in-patient hospitalizations of one or more employees • 7, 636 in-patient hospitalizations were reported • Primarily manufacturing and construction

News Just In … Prior to OSHA’s severe injury/ illness reporting rule has come to confirm: Top 5 industry groups to report severe injuries • 1 – Structure/ foundation contractors, 2 – Building equipment contractors, 3 – Mining operations, 4 – Commercial building construction and 5 – Postal services Reporting lead to very productive inspections • One-third of all severe injury/ illness reports led in wall-to-wall investigations • 58% of amputations reported resulted in investigations OSHA believes that 50% or more severe injury/ illnesses are not being reported • Found through state funded programs and self-insurers loss run reports Majority of severe reports were filed by large sized employers • OSHA is working through insurer’s and first responders to help educate small to mid-sized employers

Online Reporting Rule Effective January 1, 2017 (State Plans have until 7/1/2017) WHO? Certain industries and certain sized employers must comply: • High-risk industries WITH 20 -249 employees (Construction, transportation, utilities, warehousing, waste management, residential care facilities, commercial machinery/ equipment maintenance, wholesale trades, building materials, etc. ) • All industries with greater than 250 employees • Employers with multiple locations – must calculate the total of all combined however online reporting will be location specific HOW? OSHA will provide a secure website with a unique PIN for entry, 3 ways can occur: • Manually enter data via site using fillable PDF format • Electronically upload information via the attachment of a CSV file (X-cel) • Electronic interfacing application

Online Reporting Rule WHEN? Dates and forms for compliance are staged as such: Submission Year EOR with 250 + EE EOR with 20 -249 EE Deadline 2017 (will be 2016 records) 300 A form July 1, 2017 2018 (will be 2017 records) 300, 300 A, 301 forms 300 A form July 1, 2018 2019 - forward (will be 2018 records) 300, 300 A, 301 forms 300 A form March 2 nd WHY? OSHA has implemented this online reporting rule for various reasons: • Allows them to review trends for enforcement and aid in safety initiative programs • Allows for job-seekers, customers, and investors to review injury/illness history • Allows the Dept. of Labor to create more accurate industry injury rates

Online Reporting Rule ADDITIONAL DETAILS: • All data that is entered online will be visible to the general public however employee name and treating physician identities will be private • While online recording still excludes many small to mid-sized establishments and lower risk industries, OSHA recordkeeping forms must still be maintained internally if applicable. • While online recording applies to larger and high risk industries, these employers must still maintain and track recordkeeping forms internally.

What is a recordable injury? Injuries involving: • Death (Must report to OSHA within 8 hours) • Days away from work • Restricted work or transfer to another job • Medical treatment beyond first aid • Physical therapy / Chiropractic treatments • Loss of consciousness • Written prescriptions (dosage will make final determination) • Ibuprofen (such as Advil™) - Greater than 467 mg • Diphenhydramine (such as Benadryl™) - Greater than 50 mg • Naproxen Sodium (such as Aleve™) - Greater than 220 mg • Standard Threshold Shift in hearing in one / both ears • A significant injury or illness diagnosed by a physician or other health care professional • Licensed physician recommends medical treatment but employee refuses, it is still recordable

What is not a recordable injury? Injuries involving: • An employee injured while acting in part of the general public • Eating, drinking, preparing food for personal consumption • Personal tasks at the establishment outside of work hour • Personal: Grooming, Self-medication • Voluntary participation in: Wellness programs, Med fitness, Recreational activity • Motor vehicle accident on company lot during commute • Common cold or flu • Mental illness • Employee performing work for pay in the home and injury is due from home environment • First Aid procedures are applied • Employee in travel status…. • Checked into hotel (home away from home ) • • • Commute to job location Detour for personal reasons Leave for food consumption NOT RECORDABLE

First Aid - General Rule Injury that does not require more than first aid treatment is usually not recordable… So what is considered First Aid? • Using a non-prescription medication at non-prescription strength • Diagnostic procedures – x-ray, blood tests • Administering tetanus immunizations • Cleaning, flushing or soaking wounds on the skins surface • Using wound coverings such as bandages, gauze or butterfly bandages – Stitches will be recordable as well as surgical glue • Using hot or cold therapy • Using a non-rigid means of support, such as: wraps, elastic bandages, non rigid back belts, etc. • Drilling of a fingernail or toenail to relieve pressure • Utilization of an eye patch • Removing a foreign body from the eye using ONLY irrigation or cotton swab • Use of a finger guard, use of massages and drinking fluids for heat stress relief

OSHA Recordkeeping Forms 300 LOG • Use to list all the recordable injuries and illnesses in your workplace within 7 days • Use as a tool for detecting problems and trends within your workplace • Requires updates to be noted once exact counts are known 300 A SUMMARY • Injury and illness information will total and rollover onto this form • This form must be posted each year from Feb 1 – April 30 • Once posted this summary does not require updates to be noted 301 FORM • Use to record details about a recordable incident within 7 days • You may use an equivalent form to replace this 301 – example: BWC FROI

300

300 A

301

“Privacy Case” To protect injured employee’s privacy when forms are released – what is considered to be a private case? • Intimate body part or reproductive system • Sexual assault • Mental illness • HIV infection, hepatitis or tuberculosis • Needle stick/ sharps injuries (Record as an injury initially, however if the employee is later diagnosed with an infectious bloodborne disease, then update the log to an illness. Even if you are covered by HIPAA, disclosing OHSA 300 s containing employee PHI shouldn't get you into trouble. That's because there are exceptions within HIPAA when you're allowed to disclose PHI about individuals even without their permission. One of these exceptions is when disclosure is "required by law. "

Facts & Statistics 2015 - 20 Officers per each million employees Industry with the highest incident rate: Animal slaughtering 1/3 of all severe injury reports have initiated inspections (300 injuries per 10 K staff) Inspections will result in wall-towall inspections U. S. workers are dying every 2 hours 2014 – 184 Ohio fatalities occurred 2015 OSHA received 8, 700 severe injury reports (168 men, 16 women) 1970 OSHA had 36 Officers per each million employees

Sheakley Health & Safety Services Jillian Santel 800 -877 -5055 x. 1150 jillian. santel@sheakley. com