NEW OSHA RECORDKEEPING NEW OSHA RECORDKEEPING STANDARDSTANDARD

<Insert Company Name>

Prepared by:

Hettrick, Cyr & Associates, Inc.

BENEFITS OF THE RULEBENEFITS OF THE RULE

Improves employee involvementImproves employee involvement Creates simpler formsCreates simpler forms Provides clearer regulatory requirementsProvides clearer regulatory requirements Increases employers’ flexibility to use Increases employers’ flexibility to use

computerscomputers

DAY COUNTSDAY COUNTS

Eliminates the term “lost workdays” and Eliminates the term “lost workdays” and focuses on days away or days restricted or focuses on days away or days restricted or transferredtransferred

Includes new rules for counting that rely on Includes new rules for counting that rely on calendar days instead of workdayscalendar days instead of workdays

RECORDING CRITERIARECORDING CRITERIA

Eliminates different criteria for Eliminates different criteria for recording work-related injuries and recording work-related injuries and work-related illnesseswork-related illnesses

Former rule required employers to Former rule required employers to record all illnesses, regardless of record all illnesses, regardless of severityseverity

LOG REPORTING CHANGESLOG REPORTING CHANGES

NEW “300” log simplifiedNEW “300” log simplified Supplementary Record (OSHA 301)Supplementary Record (OSHA 301) Annual Summary (OSHA 300A); 3 Month Posting – Annual Summary (OSHA 300A); 3 Month Posting –

2/1 thru 4/302/1 thru 4/30 Signed By Company ExecutiveSigned By Company Executive Access to OSHA 301 for Employee Representatives Access to OSHA 301 for Employee Representatives

(without personal identifiers)(without personal identifiers) All Entries Within 7 Calendar DaysAll Entries Within 7 Calendar Days Day count by calendar days;180 days maximumDay count by calendar days;180 days maximum ““Lost Work Day” language eliminatedLost Work Day” language eliminatedNEW FORMS MUST BE USED BEGINNING 1/1/2002NEW FORMS MUST BE USED BEGINNING 1/1/2002

RECORDING CRITERIA RECORDING CRITERIA DECISION TREEDECISION TREE

Did the employee experience an injury or illness?

Is the injury

or illness a new case?

Is the injury or

illness work-related?

Does the injury or illness meet the general recording criteria

or the application to specific cases?

Update the previously

recorded injury or illness

entry if necessary.

NO

YES

YES

YES

YES

Record the

injury or illness

Do not record the

injury or illness

NO

NO

NO

WORK RELATEDNESSWORK RELATEDNESS

Cases are work-related if:Cases are work-related if:– An event or exposure in the work environment An event or exposure in the work environment

either caused or contributed to the resulting either caused or contributed to the resulting conditioncondition

– An event or exposure in the work environment An event or exposure in the work environment significantlysignificantly aggravated a pre-existing injury or aggravated a pre-existing injury or illnessillness

WORK RELATED EXCEPTIONSWORK RELATED EXCEPTIONS

Adds additional exceptions to the definition Adds additional exceptions to the definition of work relationship to limit recording of of work relationship to limit recording of cases involving:cases involving:– eating, drinking, or preparing food or drink for eating, drinking, or preparing food or drink for

personal consumptionpersonal consumption– common colds and flucommon colds and flu– voluntary participation in wellness or fitness voluntary participation in wellness or fitness

programsprograms– personal grooming or self-medicationpersonal grooming or self-medication

OSHA RECORDABLESOSHA RECORDABLES

DeathDeath Loss of consciousnessLoss of consciousness Days away from workDays away from work Restricted work activity or job transferRestricted work activity or job transfer Medical treatment beyond first aidMedical treatment beyond first aid ““Significant” work related injuries/illnesses as Significant” work related injuries/illnesses as

defined by physiciandefined by physician Additional criteriaAdditional criteria

RECORDING NEEDLESTICKSRECORDING NEEDLESTICKS

Requires employers Requires employers to record all to record all needlestick and needlestick and sharps injuries sharps injuries involving involving contamination by contamination by another person’s another person’s blood or other blood or other potentially infectious potentially infectious materialmaterial

HEARING LOSSHEARING LOSS

Requires employers to record 25 dB Requires employers to record 25 dB shifts in employees’ hearing during shifts in employees’ hearing during 2002 2002

OSHA will reconsider the hearing loss OSHA will reconsider the hearing loss criteria for 2003 and beyondcriteria for 2003 and beyond

MUSCULOSKELETAL DISORDERSMUSCULOSKELETAL DISORDERS

Applies the same recording criteria to Applies the same recording criteria to musculoskeletal disorders (MSDs) as to all other musculoskeletal disorders (MSDs) as to all other injuries and illnessesinjuries and illnesses

Employer retains flexibility to determine whether Employer retains flexibility to determine whether an event or exposure in the work environment an event or exposure in the work environment caused or contributed to the MSDcaused or contributed to the MSD

OSHA will use the one-year delay to develop OSHA will use the one-year delay to develop definitions of ergonomic injury and MSD definitions of ergonomic injury and MSD consistent with a comprehensive effortconsistent with a comprehensive effort

TUBERCULOSIS & MEDICAL TUBERCULOSIS & MEDICAL REMOVALREMOVAL

Includes separate Includes separate provisions describing the provisions describing the recording criteria for cases recording criteria for cases involving the work-related involving the work-related transmission of transmission of tuberculosistuberculosis

Requires employers to Requires employers to record cases of medical record cases of medical removal under OSHA removal under OSHA standardsstandards

FIRST AID NON RECORDABLES, FIRST AID NON RECORDABLES, 1986 - 20011986 - 2001

Application of Application of AntisepticsAntiseptics during during first visit first visit to medical personnelto medical personnel

Treatment of Treatment of First Degree BurnsFirst Degree Burns Application of Application of Bandages during Bandages during

any visitany visit to medical personnel to medical personnel Use of Use of Elastic Bandages during Elastic Bandages during

first visitfirst visit to medical personnel to medical personnel Removal of Removal of Foreign Bodies from Foreign Bodies from

wound; wound; if procedure is if procedure is uncomplicated,uncomplicated, and is, for and is, for example, by tweezers or other example, by tweezers or other simple techniquesimple technique

Use of Use of Non Prescription Non Prescription Medication and Medication and administration of administration of single dose of Prescription single dose of Prescription Medication Medication on first visit for minor on first visit for minor injury or discomfortinjury or discomfort

Soaking Therapy on initial visitSoaking Therapy on initial visit to medical personnel or removal of to medical personnel or removal of bandages by bandages by SoakingSoaking

Application of hot or cold Application of hot or cold Compresses during first visit Compresses during first visit to to medical personnelmedical personnel

Application of Application of OintmentsOintments to to abrasions to prevent drying or abrasions to prevent drying or crackingcracking

Application of Application of Heat Therapy Heat Therapy during first visitduring first visit to medical to medical personnelpersonnel

Negative X-Ray diagnosisNegative X-Ray diagnosis Observation Observation of injury during visit of injury during visit

to medical personnelto medical personnel Administration of Administration of Tetanus Shots Tetanus Shots

or Boosters or Boosters without serious injurywithout serious injury

FIRST AID NON RECORDABLES, FIRST AID NON RECORDABLES, 1/1/20021/1/2002

Using non-prescription Using non-prescription medications at non-prescription medications at non-prescription strengthstrength

Administering tetanus Administering tetanus immunizationsimmunizations

Cleaning, flushing, or soaking Cleaning, flushing, or soaking wounds on the skin surfacewounds on the skin surface

Using wound coverings, such Using wound coverings, such as bandages, BandAids, gauze as bandages, BandAids, gauze pads, etc., or using SteriStrips pads, etc., or using SteriStrips or butterfly bandagesor butterfly bandages

Using hot or cold therapyUsing hot or cold therapy Using any totally non-rigid Using any totally non-rigid

means of support, such as means of support, such as elastic bandages, wraps, non-elastic bandages, wraps, non-rigid back belts, etc.rigid back belts, etc.

Using temporary Using temporary immobilization devices while immobilization devices while transporting an accident victim transporting an accident victim (splints, slings, neck collars, or (splints, slings, neck collars, or back boards)back boards)

Drilling a fingernail or toenail Drilling a fingernail or toenail to relieve pressure, or draining to relieve pressure, or draining fluids from blistersfluids from blisters

Using eye patchesUsing eye patches Using simple irrigation or a Using simple irrigation or a

cotton swab to remove foreign cotton swab to remove foreign bodies not embedded in or bodies not embedded in or adhered to the eyeadhered to the eye

Using finger guardsUsing finger guards

FIRST AID NON RECORDABLES, FIRST AID NON RECORDABLES, 1/1/20021/1/2002

Using irrigation, tweezers, cotton swab, or other simple Using irrigation, tweezers, cotton swab, or other simple means to remove splinters or foreign material from areas means to remove splinters or foreign material from areas other than the eyeother than the eye

Using massages (physical therapy or chiropractic treatment Using massages (physical therapy or chiropractic treatment considered medical treatment under new standard)considered medical treatment under new standard)

Drinking fluids to relieve heat stressDrinking fluids to relieve heat stress

THIS IS A COMPLETE LIST OF ALL TREATMENTS THIS IS A COMPLETE LIST OF ALL TREATMENTS

CONSIDERED FIRST AID, NON-RECORDABLECONSIDERED FIRST AID, NON-RECORDABLE

MEDICAL TREATMENT RECORDABLESMEDICAL TREATMENT RECORDABLES1986 - 20011986 - 2001

Treatment of InfectionTreatment of Infection Application of Antiseptics during Application of Antiseptics during

second or subsequent visit to medical second or subsequent visit to medical personnelpersonnel

Treatment of Second or Third Degree Treatment of Second or Third Degree BurnsBurns

Application of Sutures (Stitches)Application of Sutures (Stitches) Application of Butterfly Adhesive Application of Butterfly Adhesive

Dressings or Steri Strips in lieu of Dressings or Steri Strips in lieu of suturessutures

Removal of Foreign Bodies Embedded Removal of Foreign Bodies Embedded in Eyein Eye

Removal of Foreign Bodies from Removal of Foreign Bodies from Wound; if procedure is complicated Wound; if procedure is complicated because of depth of embedment, size, or because of depth of embedment, size, or locationlocation

Use of Prescription Medications (except Use of Prescription Medications (except a single dose administered on first visit a single dose administered on first visit for minor injury or discomfortfor minor injury or discomfort

Use of hot or cold Soaking Therapy Use of hot or cold Soaking Therapy during second or subsequent visit to during second or subsequent visit to medical personnelmedical personnel

Application of hot or cold Compresses Application of hot or cold Compresses during second or subsequent visit to during second or subsequent visit to medical personnelmedical personnel

Cutting away Dead Skin (surgical Cutting away Dead Skin (surgical debridement)debridement)

Application of Heat Therapy during Application of Heat Therapy during second or subsequent visit to medical second or subsequent visit to medical personnelpersonnel

Use of Whirlpool Bath Therapy during Use of Whirlpool Bath Therapy during second or subsequent visit to medical second or subsequent visit to medical personnelpersonnel

Positive X-Ray diagnosis (fractures, Positive X-Ray diagnosis (fractures, broken bones, etc.)broken bones, etc.)

Admission to a Hospital or equivalent Admission to a Hospital or equivalent medical facility for treatmentmedical facility for treatment

MEDICAL TREATMENTMEDICAL TREATMENTThe Management and Care of a Patient to The Management and Care of a Patient to

Combat Disease or DisorderCombat Disease or Disorder

Not Considered Medical Treatment:Not Considered Medical Treatment:

Visits to a doctor or health care professional solely for observation or Visits to a doctor or health care professional solely for observation or counselingcounseling

The conduct of diagnostic procedures, such as x-rays and blood tests, The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely including the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils; orfor diagnostic purposes (e.g., eye drops to dilate pupils; or

First Aid as defined in the new standardFirst Aid as defined in the new standard

EMPLOYEE PRIVACYEMPLOYEE PRIVACY

Prohibits employers from entering an individual’s Prohibits employers from entering an individual’s name on Form 300 for certain types of injuries/illnesses name on Form 300 for certain types of injuries/illnesses

Provides employers the right not to describe the nature Provides employers the right not to describe the nature of sensitive injuries where the employee’s identity of sensitive injuries where the employee’s identity would be knownwould be known

Gives employee representatives access only to the Gives employee representatives access only to the portion of Form 301 which contains no personal portion of Form 301 which contains no personal informationinformation

Requires employers to remove employees’ names Requires employers to remove employees’ names before providing the data to persons not provided before providing the data to persons not provided access rights under the ruleaccess rights under the rule

PRIVACY CASE ENTRIESPRIVACY CASE ENTRIES Injury or illness to an intimate body part or to Injury or illness to an intimate body part or to

reproductive systemreproductive system Injury or illness resulting from sexual assaultInjury or illness resulting from sexual assault A mental illnessA mental illness HIV infection, hepatitis, or TBHIV infection, hepatitis, or TB A needlestick or sharps contaminated by blood or A needlestick or sharps contaminated by blood or

infectious materialinfectious material Voluntary employee request of illness caseVoluntary employee request of illness case

RECORD “PRIVACY CASE” IN NAME COLUMNRECORD “PRIVACY CASE” IN NAME COLUMN

EMPLOYEE INVOLVEMENTEMPLOYEE INVOLVEMENT

Requires employers to establish a procedure Requires employers to establish a procedure for employees to report injuries and for employees to report injuries and illnesses and tell their employees how to illnesses and tell their employees how to reportreport

Employers are Employers are prohibitedprohibited from from discriminating against employees who do discriminating against employees who do reportreport

Employee representatives will now have Employee representatives will now have access to those parts of the OSHA 301 form access to those parts of the OSHA 301 form relevant to workplace safety and healthrelevant to workplace safety and health

REPORTING TO OSHA REPORTING TO OSHA

Changes the reporting of fatalities and Changes the reporting of fatalities and catastrophes to exclude some public catastrophes to exclude some public transportation and motor vehicle transportation and motor vehicle accidents, but adds heart attack accidents, but adds heart attack fatalitiesfatalities