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Transcript of OSHA Injury & Illness Recordkeeping - KellerOnline€¦ · OSHA Injury & Illness Recordkeeping:...
OSHA Injury & Illness Recordkeeping
Will your records stand inspection?
Copyright © 2010 J. J. Keller & Associates, Inc. All rights reserved.
Due to the constantly changing nature of government regulations, it is impossible to guarantee the total and absolute accuracy of the material contained herein or presented. J. J. Keller & Associates, Inc., cannot and
does not assume any responsibility for omissions, errors, misprinting or ambiguity contained. J. J. Keller,
shall not be held liable in any degree for any loss, damage or injury caused by any such omission, error, misprinting or ambiguity present. It is made available
with the understanding that J. J. Keller is not engaged in rendering legal, accounting or other professional service. If legal advice or other expert service is
required, the services of a competent professional should be sought.
Copyright © 2010 J. J. Keller & Associates, Inc. All rights reserved.
Presented by KellerOnline®
KellerOnline® provides several resources on today’s topic:
– Topic Index (LOIs, ez Explanations, FAQs)• Recordkeeping (Injury & Illness)• National Emphasis Program (NEP)
– Incidents (Form 300/301) Recordkeeping Tool• Incident Portal – Coming Soon!
– Workers’ Compensation Recordkeeping Tool– Safety Training Programs– Safety Plans– Interactive Forms
© 2010 J. J. Keller & Associates, Inc.® 1
KellerOnline® Webcast – January 26, 2010 OSHA Injury & Illness Recordkeeping: Will your records stand inspection?
Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
National Emphasis Program
• Low DART rates in high rate industries• Lack of record completeness• 40 or more employees• DART rate of 4.2 or less
Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
What is the NEP?
Three objectives:• Ensure employers are recording injuries and
illnesses• Determine accuracy of injury and illness rate data• Determine what role occupational physicians play in
reporting data
Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
H1N1 Influenza
Common cold and flu is not recordableH1N1 Influenza A virus is recordable if:
Confirmed as 2009 H1N1Work-relatedMeets recording criteria
Employer’s responsibility to determine
© 2010 J. J. Keller & Associates, Inc.® 2
Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
Musculoskeletal Disorders
Currently no WMSD recording requirementCurrently no 300 Log column for WMSDLast year, OSHA developed a proposed rule to add:
Definition for WMSDsAn WMSD column on the 300 Log
Help track WMSD injuriesProvide improved statistics on WMSD
Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
Occupational injuries and illnesses
Lots of ‘gray’ recordkeeping areas• Work-related• Medical treatment• OTC meds• Parking lots• Breaks• Temps• Travel • Counting days• Exemptions
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Recordkeeping forms
Forms:OSHA 300 Log301 Incident Report300A Summary
*These forms can be found in KOL in the Topic Index > Recordkeeping.
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
Partial exemptions for:
Company size: 10 or fewer employeesLow hazard industry: 75% below the national average
Who’s covered by the rule
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ALL employers must report
Work-related fatalitiesHospitalization of 3 or more workersCall the hotline 800-321-OSHA
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Who is a covered employee?
All employees on your payroll:
Salaried/Hourly Labor/ExecutiveSeasonal/Migrant Full-time/Part-timeTemporary/Leased
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
Daily supervision
Each case is recorded only once
If you supervise:Your 300 LogIf the leasing agencysupervises:Agency’s 300 Log
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Poll question
Does the fact that an employee reports that he or she was injured in the workplace mean you have to record it?
YesNo
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Poll question
“The mere reporting . . . does not make itrecordable . . .”
Employer must determineif an injury or illness hasoccurred
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
1. Work-related
In the work environmentcaused or contributed to the conditionpresumed for injuriesand illnessesdiscernable cause orsignificant aggravationneed not be the soleor predominant cause
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2. New case
No previous injury to the body part
OR
Completely recoveredFrom the injury
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3. Recording criteria
General recording criteriaDeathDays awayRestrictionTransferMedical treatmentLoss of consciousnessSignificant injury or illness
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
3. Recording criteria
Specific recording criteriaContaminated sharpsHearing lossTuberculosisMedical removal
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General recording criteria
1. DeathReported within 8 hoursHeart attacks
2. Days away from workHealthcare professionalEmployer
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3. Loss of consciousness
4. Diagnosis of a significant injury/illness
General recording criteria
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
General recording criteria
5. Restricted workOne or more routine job functions, orKeeps employee from working a full day.
6. Job transfer“….assigning to
another job forpart of the dayor a full day….”
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General recording criteria
7. Medical treatment beyond first aidFirst aid treatments listed at 1904.7(b)(5)(ii)
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Poll question
Are insect bites and stings recordable?YesNoOnly if it meets the criteria
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
Poll question
If the case meets the recording criteria, it’s recordable
Most bites and stingswon’t be recordable
Recordable even ifemployee “self-injects”
Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
What is first aid?
Nonprescription medication at nonprescription strengthTetanus shotsCleaning, flushing or soaking wounds on the surface of the skinWound coveringsHot or cold therapyNon-rigid means of supportTemporary immobilization devices
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What is first aid?
Drilling a fingernail or toenail, or draining a blisterEye patchesRemoving foreign bodies from the eye using only irrigation or a cotton swabRemoving splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple meansFinger guardsMassagesDrinking fluids for relief of heat stress
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
Wound coverings vs. closings
Not recordable:Band-aidsButterfly bandagesSteri-stripsLiquid bandages
Recordable:SuturesStaplesSurgical glues
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Medical treatments
Not recordable:Diagnostic proceduresCounselingMassage
Recordable:ManipulationWork restrictions
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Contemporaneous opinion
. . . Occurring at the same time . . . “More authoritative”Treatment has not occurredExamination in sametime frameNo prescription waswritten
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Non-prescription drugs given at prescription strength
Single doses of common OTC drugs taken at prescription strength are recordable
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Non-prescription drugs given at prescription strength
Ibuprofen < 467 mgDiphenhydramine < 50 mgNaproxen Sodium < 220 mgKetoprofen < 25 mg
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Prescription-strength medications
Recordable:Sample prescription medsOTCs at prescription strengthPrescriptions given but not filledPreventative medicines
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
Bloodborne pathogens
Needlestick and sharps injuries are recordable if contaminated with:
1.Blood2.Body fluids
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Bloodborne pathogens
Must update the 300 Log if it results in:DeathDays away from workRestricted workJob transfer
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Hearing loss
Standard threshold shift (STS)
Audiometric zero
Work-related
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
Hearing loss example
40353025
30 annual
201510
50 audiometric
20 baseline 20 annual
10 baseline
Recordable Not recordable
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Medical removal
It is recordable if:Removal required by other OSHA standards
It is NOT recordable if:Voluntarily before medical removal levels occur
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Oxygen
It is recordable if:Given to relieve symptoms
It is NOT recordable if:Given as a precaution
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
Travel status
Injuries or illnesses occurring to employees on “travel status” are work-related the employee was engaged in work activities in the interest of the employerIt is not recordable if the employee was:
In a “home away from home”Taking a detour for personal reasons
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Loss of consciousness
It is recordable if:Complete loss of consciousnessRegardless of timeApplies to mandatory medical procedures
It is NOT recordable if:Results from personal medical conditionOnly become light-headed
Must be work-related.
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How to count
Do NOT count thefirst dayPartial days ofwork areconsidered to berestricted daysMust record within7 days
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How to count
Count calendar daysNOT
work daysNo partial daysCap count at 180days
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How to count
Record each case only onceLog all days in the year the injury occursEstimate days if needed for theSummary
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Recording exceptions
1. Employee present as member of general public
2. Symptoms which surface at work
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Recording exceptions
3. Voluntaryparticipation in wellness programs or recreational activity
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Recording exceptions
4. Eating, drinking, or preparing food brought from home or purchased in the workplace
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Recording exceptions
5. The injury or illness resulted from:Personal tasks are unrelated to employment, andThe activity wasperformed outsideof assigned workhours
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Recording exceptions
6. Injuries that are solely the result of:Personal groomingSelf-medication for non-work conditionIntentionally self-inflicted
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Poll question
An employee falls down, breaks his arm, and fails a post-accident drug test. Can you stop the day count when you terminate?
YesNoIt depends
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Poll question
OSHA allows you to stop your count . . .for reasons unrelated to the injury.
The drug test isrelated to the injury
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Recording exceptions
7. Vehicle accidents in company parking lots or access roads during a commute
Employer controlPublic parking lots
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Recording exceptions
8. Common cold and fluvs. Other infectiousdiseases
9. Mental illness
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300A Summary
Post between February 1st and April 30thMust be certified by a “company executive”A “company executive” is:
An owner;An officer of the corporation;The highest ranking official at the establishment; orThe immediate supervisor of the highest ranking company official working at the establishment.
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
To review
To be recordable:work-relatednew casemeet recording criteria
List of first aid treatments is comprehensive –anything not on the list is medical treatment
Post 300A from Feb. 1st through April 30th
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Recordkeeping in KellerOnline
Incident Portal
Coming Soon!
Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
Recordkeeping in KellerOnline
Incident Portal
Coming Soon!
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Copyright © 2010 J. J. Keller & Associates, Inc.® All rights reserved.
Questions?
If you have questions, please use the Q&A function in the upper right of your screen. If we don’t get to your question today, please use
the Personal Assistant feature (shown below).
Thank you for participating!
Bloodborne Pathogens Standard will be presented on
Wednesday, February 24th @ 1PM Central Time
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