WABA Workshop July 2019

To the injury recordkeeping

tutorial! We know recordkeeping

can be confusing and time-

consuming. We have included

information which is easy to

navigate and addresses

frequently asked questions.

Employers will be able to identify recordable injury or illness.

Fill out the required OSHA 300 Forms

Recognize when to report injury or fatality incidents to OSHA.

Who is exempt?

Have access to resources available to locate information as needed pertaining to the OSHA 300 log.

Who is OSHA? What is an OSHA log? The Occupational Safety and Health Act of 1970 was enacted by Congress

creating OSHA: the Occupational Safety and Health Administration. Our

mission is to help employers reduce on-the-job injuries, illnesses, and deaths.

When an employee is injured, it is the responsibility of the employer

to record it on an OSHA log. This record helps OSHA determine

who is getting injured and how.

• Offers flexibility by letting employers computerize injury and illness records;

• Updates three recordkeeping forms: – OSHA Form 300 (Log of Work-Related Injuries and Illnesses); simplified and

reformatted to fit legal size paper. [Download Recordkeeping Forms]

– OSHA Form 301 (Injury and Illness Incident Report); includes more data about how the injury or illness occurred.

• OSHA Form 300A (Summary of Work-Related Injuries and Illnesses); separate form created to make it easier to calculate incidence rates;

• Continues to exempt smaller employers (employers with 10 or fewer employees) from most requirements;

• Changes the exemptions for employers in service and retail industries;

Clarifies the definition of work relationship, limiting the recording of pre-existing cases and adding new exceptions for some categories of injury and illness;

Includes new definitions of medical treatment, first aid, and restricted work to simplify recording decisions;

Eliminates different criteria for recording work-related injuries and work-related illnesses; one set of criteria will be used for both;

Changes the recording of needle stick injuries and tuberculosis;

Simplifies the counting of days away from work, restricted days and job transfer;

Improves employee involvement and provides employees and their representatives with access to the information; and

Protects privacy for injured and ill workers.

Simplified, clearer definitions also make it easier for employers to determine which cases must be recorded. Posting an annual summary of workplace injuries and illnesses for a longer period of time improves employee access to information, and as employees learn how to report workplace injuries and illnesses, their involvement and participation increase.

• Employers not exempt from OSHA's recordkeeping requirements must prepare and maintain records of work-related injuries and illnesses. You need to review Title 29 of the Code of Federal Regulations (CFR) Part 1904-"Recording and Reporting Occupational Injuries and Illnesses," to see exactly which cases to record. * Use the Log of Work-Related Injuries and Illnesses (Form 300) to list injuries and illnesses and track days away from work, restricted, or transferred. * Use the Injury and Illness Report (Form 301) to record supplementary information about recordable cases. You can use a workers' compensation or insurance form, if it contains the same information. * Use the Summary (Form 300A) to show totals for the year in each category. The summary is posted from February 1 to April 30 of each year.

• Recordkeeping is a critical part of an employer's safety and health efforts for several reasons: Keeping track of work-related injuries and illnesses can help you prevent them in the future.

• Using injury and illness data helps identify problem areas. The more you know, the better you can identify and correct hazardous workplace conditions.

• You can better administer company safety and health programs with accurate records.

• As employee awareness about injuries, illnesses, and hazards in the workplace improves, workers are more likely to follow safe work practices and report workplace hazards. OSHA compliance officers can rely on the data to help them properly identify and focus on injuries and illnesses in a particular area. The agency also asks about 80,000 establishments each year to report the data directly to OSHA, which uses the information as part of its site-specific inspection targeting program. The Bureau of Labor Statistics (BLS) also uses injury and illness records as the source data for the Annual Survey of Occupational Injuries and Illnesses that shows safety and health trends nationwide and industrywide.

Reporting fatalities and catastrophes: All employers covered by the Occupational Safety and Health Act of 1970 (P.L. 91-596) must report to OSHA any workplace incident resulting in a fatality within 8 hours or any amputation, in-patient hospitalization of one employee or the loss of an eye need to be reported within 24 hours.

Keeping injury and illness records: If you had 10 or fewer

employees during all of the last calendar year or your business is classified in a specific low-hazard retail, service, finance, insurance, or real estate industry, you do not have to keep injury and illness records unless the Bureau of Labor Statistics or OSHA informs you in writing that you must do so.

• 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 § 1904.41 or § 1904.42. However, as required by § 1904.39, all employers covered by the OSH Act must report to OSHA any workplace incident that results in a fatality, amputation, in-patient hospitalization of one employee or the loss of an eye.

If your company had more than ten (10) employees at any time during the last calendar year, you must keep OSHA injury and illness records unless your establishment is classified as a partially exempt industry under § 1904.2.

This Subpart describes the work-related injuries and illnesses that an employer must enter into the OSHA records and explains the OSHA forms that employers must use to record work-related fatalities, injuries, and illnesses.

Each employer required by this Part to keep records of fatalities, injuries, and illnesses must record each fatality, injury and illness that:

1904.4(a)(1) Is work-related; and1904.4(a)(2) Is a new case; and1904.4(a)(3) Meets one or more of the general recording criteria of § 1904.7 or the application to specific cases of § 1904.8 through § 1904.12.

The decision tree for recording work-related injuries and illnesses below shows the steps involved in making this determination.

Is the partial exemption for size based on the size of my entire company or on the size of an individual business establishment?

* The partial exemption for size is based on the number of employees in the entire company.

Section 11(c) of the Act prohibits you from discriminating against an employee for reporting a work-related fatality, injury or illness. That provision of the Act also protects the employee who files a safety and health complaint, asks for access to the Part 1904 records, or otherwise exercises any rights afforded by the OSH Act.

Calculating OSHA Injury and Illness Incidence Rates Each year, the Occupational Safety and Health Administration (OSHA) collects work-related injury and illness data from employers. This data collection is called the OSHA Data Initiative (ODI). The data provided is used by OSHA to calculate establishment-specific injury and illness incidence rates. An incidence rate is the number of recordable injuries and illnesses occurring among a given number of full-time workers (usually 100 full-time workers) over a given period of time (usually one year). An employer may want to evaluate its injury and illness experience over time or compare its experience with that of the industry as a whole. This is called an employer’s incidence rate. These rates can help identify problems in the workplace and progress made in preventing work-related injuries and illnesses.

INCIDENCE RATE—KEY TERMS • The total case rate (TCR) includes all cases recorded on the OSHA Form 300 • The days away, restricted and transfer (DART) includes cases recorded in Column H + Column I. • The days away from work (DAFW) includes cases recorded in Column H. • To determine the total number of hours all employees actually worked during the year, please refer to OSHA Form 300A.

COMPUTING THE INCIDENCE RATE Employers can use a formula to compute an occupational injury and illness incidence rate for all recordable cases or for cases that involved days away from work. Before computing the rate, employers must determine: • Total recordable cases – The total case rate (TCR) includes all cases recorded on the OSHA Form 300 (Column G + Column H + Column I + Column J). • Cases involving days away from work – The days away, restricted and transferred (DART) includes cases recorded in Column H + Column I. The days away from work (DAFW) includes cases recorded in Column H. • Total hours all employees actually worked during the year – Refer to OSHA Form 300A and optional worksheet to calculate this number.

FORMULA Once the items described above are determined, an employer can compute the incidence rate of injuries and illnesses using the following formula: Number of injuries and illnesses x 200,000 = Incidence rate or total recordable case rate Employee hours worked

ACTIVITY & INITIATIVES Improve Tracking of Workplace Injuries and Illnesses, 1218-AC49 NPRM was published on Nov. 8, 2013; Final Rule issued March 2016 • Does not add or change recording criteria or definitions in part 1904 • Modifies how employers transmit Recordkeeping records to OSHA • Changes how many establishments submit, what has to be submitted and how often – Details: • Requires covered establishments with more than 250 employees to submit their 1904 data electronically each quarter

• Will collect case-specific data on ~900,000 work related injuries and illnesses from 38,000 establishments. Case-specific data includes information about nature and source of the injury or illness and event/exposure that led to it. • Will collect OSHA Form 300A from 440,000 establishments with 20 or more

employees that have an industry DART rate over 2.0. • The modernized system replaces OSHA's ODI annual survey (which currently goes out to 80,000 high-hazard establishments)

Recordable accidents

Fill out form 300

Follow Step-by-step process to identify the recordable and non-recordable accidents

Partial exemption based on company size.