OSHA Logs: How To Do Them Right!

– KPA CONFIDENTIAL –

OSHA Logs: How To Do Them Right!

November 18, 2010

SpeakersSpeakers

– KPA CONFIDENTIAL –

Rob SinghNorthwest District Manager

Moderator Presenter

Becky RossMarketing Manager

QuestionsQuestions

3– KPA CONFIDENTIAL –

•If you have questions during the presentation, please submit them using the “Questions” feature

• All questions will be answered at the end of the webinar

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The Next Generation of Environmental, Health, and Safety (EHS) Services from KPA

We have expanded our EHS services from three levels to seven, and we have added new features to our existing services and software.

View the Details at: http://www.kpaonline.com/ehs/products-and-services.html

ProCore PlusCoreFundamental PlusFundamentalElementsDOT and MSDS

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Why Safety?Why Safety?Why Safety?Why Safety?

Not Always “Common Sense”Not Always “Common Sense”Not Always “Common Sense”Not Always “Common Sense”

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Ultimately Safety is RelativeUltimately Safety is Relative

Safety Metrics that Make Sense – Safety Metrics that Make Sense – Measuring the Costs of LossMeasuring the Costs of Loss

Safety Metrics that Make Sense – Safety Metrics that Make Sense – Measuring the Costs of LossMeasuring the Costs of Loss

• Total OSHA Recordable Case Rate – Used to identify average number of recordable injuries per one hundred employees

• Experience Modification Rate

• Total number of claims per quarter/year?

• Avg. Costs per claim?

• Number of regulatory inquiries, visits in year?

• Number and amount of regulatory fines

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Why OSHA Logs?Why OSHA Logs?Why OSHA Logs?Why OSHA Logs?

• History: • Indication of safety performance (or

non performance)!• Is the LAW!• Allows for Loss Control Management. • Allows Govt. to compile State and

Federal Industry Injury and Illness and fatality data.

• Keeps safety in the forefront. • Promotes incentive based programs. • Used as a business climate indicator.

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Who Has To Fill Out Logs?Who Has To Fill Out Logs?Who Has To Fill Out Logs?Who Has To Fill Out Logs?

• All employers covered by the Occupational Safety and Health Act (OSH Act) are covered by Part 1904 regulations and required to keep logs. However exemptions do exists.

• 10 or fewer employees (Small Employer Exemption)

• If your company had ten (10) or fewer employees at all times during the last calendar year, you do not need to keep OSHA injury and illness records unless OSHA or the BLS informs you in writing that you must keep records under Section 1904.41 or Section 1904.42.

• Small employer exemption does not apply if 11 “count” is achieved in any given time.

• “Low Hazard” Industries (retail, service, finance, insurance or real estate industry

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Who Has to Fill Out OSHA Logs?Who Has to Fill Out OSHA Logs?Who Has to Fill Out OSHA Logs?Who Has to Fill Out OSHA Logs?

Note: All employees irrespective of Small Employer or Low Hazard Industry Exemption have to report workplace fatalities and hospitalization of 3 or more employees. Also, understand day to day supervision of temp employee rules. In addition to the fact that the establishment, rather than the firm, is the appropriate unit for determining the SIC code. This relates to the “close proximity” debate


Components of the LogComponents of the Log

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(i) Determination of work-relatedness.

(ii) Determination of a new case.

(iii)General recording criteria.

(iv)Additional criteria. (Needlestick and sharps injury cases, tuberculosis cases, hearing loss cases, medical removal cases, and musculoskeletal disorder cases).

OSHA 300 LogOSHA 300 Log

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How Do I Decide if a Injury is Recordable?How Do I Decide if a Injury is Recordable?


Definition of Work Environment.Definition of Work Environment.


Definition of Work EnvironmentDefinition of Work Environment


Travel:

Injuries and illnesses that occur while an employee is on travel status are work-related if, at the time of the injury or illness, the employee was engaged in work activities "in the interest of the employer." Examples of such activities include travel to and from customer contacts, conducting job tasks, and entertaining or being entertained to transact, discuss, or promote business (work-related entertainment includes only entertainment activities being engaged in at the direction of the employer).

Home Office:

Injuries and illnesses that occur while an employee is working at home, including work in a home office, will be considered work-related if the injury or illness occurs while the employee is performing work for pay or compensation in the home, and the injury or illness is directly related to the performance of work rather than to the general home environment or setting.

A work-related injury or illness must be recorded if it results in one or more of the following:

(i) Death.

(ii) Days away from work.

(iii) Restricted work or transfer to another job.

(iv) Medical treatment beyond first aid.

(v) Loss of consciousness.

(vi) A significant injury or illness diagnosed by a physician or other licensed health care professional.

– KPA CONFIDENTIAL – 17171717http://www.youtube.com/watch?v=QC70vdm4Al0

Definition “Injury and Illness”. What cases must I Definition “Injury and Illness”. What cases must I report?report?

Definition “Injury and Illness”. What cases must I Definition “Injury and Illness”. What cases must I report?report?

Definition of Medical TreatmentDefinition of Medical Treatment

• "Medical treatment" means the management and care of a patient to combat disease or disorder. It does not include:

(A) Visits to a physician or other licensed health care professional solely for observation or counseling;

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

(C) "First aid" as defined in paragraph (b)(5)(ii) of this section.

– KPA CONFIDENTIAL – 18

Definition of First AidDefinition of First Aid

(A) Using a nonprescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes).

(B) Administering tetanus immunizations (other immunizations, such as hepatitis B vaccine or rabies vaccine, are considered medical treatment).

(C) Cleaning, flushing or soaking wounds on the surface of the skin;

(D) Using wound coverings, such as bandages, Band-Aids®, gauze pads, etc.; or using butterfly bandages or Steri-Strips® (other wound closing devices, such as sutures, staples, etc. are considered medical treatment);

(E) Using hot or cold therapy;

(F) Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);

(G) Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.)


Definition of First Aid Cont. Definition of First Aid Cont.


(H) Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;

(I) Using eye patches;

(J) Removing foreign bodies from the eye using only irrigation or a cotton swab;

(K) Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means;

(L) Using finger guards;

(M) Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes);

(N) Drinking fluids for relief of heat stress.

Filling out the LogFilling out the Log

• Case must be entered with 7 days. • Use unique case number• Do not forget to fill out “301” form• Count first day after injury for lost and

restricted time (use calendar days)• Maintain “live log” and update as

necessary.• Do not post publicly.• Understand “sensitive cases”

– Do not enter name of workers for cases involving, intimate body part or the reproductive system, sexual assault, HIV or hepatitis infection, tuberculosis, mental illness or other similar cases.


Lost Day CasesLost Day Cases

• Day counts (days away or days restricted)– Count the number of calendar days the

employee was unable to work (include

weekend days, holidays, vacation days, etc.)– Cap day count at 180 days away and/or days

restricted– May stop day count if employee leaves

company for a reason unrelated to the injury

or illness– If a medical opinion exists, employer must

follow that opinion


Restricted Day CasesRestricted Day Cases

• Record if the case involves

one or more days of restricted

work or job transfer• Check the box for

restricted/transfer cases and

count the number of days• Do not include the day of

injury/illness



Restricted work activity exists if the

employee is:

• Unable to work the full workday he or she

would otherwise have been scheduled to

work; or• Unable to perform one or more routine job

functions• An employee’s routine job functions are

those activities the employee regularly

performs at least once per week

Note: 4 hours is usual cutoff designation between RWD and LWD



A case in not recordable as a restricted case if:

• The employee experiences minor musculoskeletal

discomfort,• A health care professional determines that the

employee is fully able to perform all of his or her

routine job functions, and• The employer assigns a work restriction to that

employee for the purpose of preventing a more

serious condition from developing.


Job TransferJob Transfer

Job transfer description –

• An injured or ill employee is assigned to a job other than his or her regular job for part of the day

• A case is recordable if the injured or ill employee

performs his or her routine job duties for part

of a day and is assigned to another job for the rest

of the day


Bloodborne Pathogen CasesBloodborne Pathogen Cases

Record all work-related needlesticks and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material (includes human bodily fluids, tissues and organs; other materials infected with HIV or HBV such as laboratory cultures)

Record splashes or other exposures to blood or other potentially infectious material if it results in diagnosis of a bloodborne disease or meets the general recording criteria


Hearing Loss CasesHearing Loss Cases

Must record all work-related hearing loss cases where:

• Employee has experienced a Standard Threshold Shift (STS)1, and

• Employee’s hearing level is 25 decibels (dB) or more above audiometric zero [averaged at 2000,3000, and 4000 hertz (Hz)] in the same ears as the STS

• STS – Avg. change of threshold of 10db.


Tuberculosis CasesTuberculosis Cases

• Record a case where an employee is exposed at work to someone with a known case of active tuberculosis, and subsequently develops a TB infection

• A case is not recordable when:– The worker is living in a household with

a person who is diagnosed with active TB

– The Public Health Department has identified the worker as a contact of an individual with active TB

– A medical investigation shows the employee’s infection was caused by exposure away from work


Annual 300 A SummaryAnnual 300 A Summary

• A company executive must certify the summary:

– An owner of the company– An officer of the corporation– The highest ranking company official

working at the establishment, or his or her supervisor

• Must post for 3-month period from February 1 to April 30 of the year following the year covered by the summary


300 A Summary300 A Summary


Non Compliance/Non ConformanceNon Compliance/Non Conformance

• Injury and Illness Recordkeeping National Emphasis Program (Sept. 2010)

– Records review for CY 2008 and CY 2009, interviews, and a walkaround (safety and health inspection) of the workplace.

– Fines in the 100k range.

• OSHA Data Initiative

• BLS Surveys


QUESTIONSQUESTIONSQUESTIONSQUESTIONS

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KPA New Products!KPA New Products!


The Next Generation of Environmental, Health, and Safety (EHS) Services from KPA

We have expanded our EHS services from three levels to seven, and we have added new features to our existing services and software.

View the Details at: http://www.kpaonline.com/ehs/products-and-services.html

ProCore PlusCoreFundamental PlusFundamentalElementsDOT and MSDS

Contact InformationContact Information


The recorded webinar and presentation slides will be emailed to you today including your local representative’s contact information.

www.kpaonline.com

[email protected]

866-356-1735Rob Singh

Northwest District Manager

[email protected]

(510) 493-7492

OSHA Logs: How To Do Them Right!

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Transcript of OSHA Logs: How To Do Them Right!