This document provides an overview and outline of an OSHA recordkeeping training on new regulations for recording work-related injuries and illnesses. It discusses key topics like defining a recordable case, determining if an injury occurred in the work environment, medical treatment vs. first aid, and rules for counting days away from work or in a job transfer due to an injury or illness. The training aims to help employers understand and comply with updated OSHA recordkeeping requirements.

1. OSHA Recordkeeping Training –OSHA Recordkeeping Training –
New RegulationNew Regulation

2. Course OutlineCourse Outline
1.0 Overview1.0 Overview
2.0 Recording Injuries & Illnesses2.0 Recording Injuries & Illnesses
3.0 Maintenance & Retention of Records3.0 Maintenance & Retention of Records
4.0 Posting Requirements4.0 Posting Requirements

3. 1.0 Overview1.0 Overview
 Federal OSHA, under ClintonFederal OSHA, under Clinton
Administration, made changes to theAdministration, made changes to the
requirements for recording work relatedrequirements for recording work related
injuries and illnesses.injuries and illnesses.
 California must adopt a regulation asCalifornia must adopt a regulation as
effective by the end of December.effective by the end of December.

4. ““Records” Consist of ThreeRecords” Consist of Three
FormsForms
 OSHA 300: Log of Occupational InjuriesOSHA 300: Log of Occupational Injuries
and Illnessesand Illnesses
 OSHA 300A : Annual Summary ofOSHA 300A : Annual Summary of
Occupational Injuries and IllnessesOccupational Injuries and Illnesses
 OSHA 301: The Supplementary Record ofOSHA 301: The Supplementary Record of
Occupational Injury and Illnesses.Occupational Injury and Illnesses.
Equivalent to Form 5020, Employer’sEquivalent to Form 5020, Employer’s
Report of Occupational Injury or IllnessReport of Occupational Injury or Illness

5. 2.0 Recording Injuries &2.0 Recording Injuries &
IllnessesIllnesses
 ““Recordable” Cases onlyRecordable” Cases only
 Recording an injury or illness under theRecording an injury or illness under the
OSHA System does not imply that anOSHA System does not imply that an
employer was at fault, that the worker wasemployer was at fault, that the worker was
at fault, that a violation of an OSHAat fault, that a violation of an OSHA
standard has occurred. Or that the injury orstandard has occurred. Or that the injury or
illness will be compensable under Workers’illness will be compensable under Workers’
Compensation.Compensation. It is not an admission ofIt is not an admission of
liability.liability.

6. Key TermsKey Terms
 Recordable:Recordable: Any work-related injury or illnessAny work-related injury or illness
in the work environment that is a new case andin the work environment that is a new case and
results in:results in:
1.1. Loss of consciousnessLoss of consciousness
2.2. Restricted work activity or job transferRestricted work activity or job transfer
3.3. Days away from work not counting the day of injuryDays away from work not counting the day of injury
4.4. Medical treatment beyond first aidMedical treatment beyond first aid
5.5. FatalityFatality
6.6. Diagnosed occupational illnessDiagnosed occupational illness

7. DefinitionDefinition
 Work Environment – The establishment &Work Environment – The establishment &
other locations where one or moreother locations where one or more
employees are working or are present as aemployees are working or are present as a
condition of their employment. The workcondition of their employment. The work
environment includes not only physicalenvironment includes not only physical
locations, but also the equipment orlocations, but also the equipment or
materials used by an employee during thematerials used by an employee during the
course of his/her work.course of his/her work.

8. Clarification – WorkClarification – Work
Environment is Not:Environment is Not:
 If the employee was injured when in theIf the employee was injured when in the
work environment as a member of thework environment as a member of the
general publicgeneral public
 The injury/illness involves signs orThe injury/illness involves signs or
symptoms that surface at work but resultsymptoms that surface at work but result
solely from a non-work-related event thatsolely from a non-work-related event that
occurs outside the work environmentoccurs outside the work environment
 The injury/illness results solely fromThe injury/illness results solely from
voluntary participation in a wellnessvoluntary participation in a wellness
program or in a medical, fitness, orprogram or in a medical, fitness, or
recreational activityrecreational activity

9. Clarification – WorkClarification – Work
Environment is Not:Environment is Not:
 The injury/illness is solely the result of anThe injury/illness is solely the result of an
employee eating, drinking, or preparingemployee eating, drinking, or preparing
food or drink for personal consumption.food or drink for personal consumption.
 The injury/illness is solely the result of anThe injury/illness is solely the result of an
employee doing personal tasks at theemployee doing personal tasks at the
establishment outside of the employee’sestablishment outside of the employee’s
assigned working hours.assigned working hours.
 The injury/illness is solely the result ofThe injury/illness is solely the result of
personal grooming, self-medication for apersonal grooming, self-medication for a
non-work-related condition or isnon-work-related condition or is
intentionally self-inflicted.intentionally self-inflicted.

10. Clarification – WorkClarification – Work
Environment is Not:Environment is Not:
 The injury/illness is caused by a motorThe injury/illness is caused by a motor
vehicle accident & occurs on a companyvehicle accident & occurs on a company
parking lot or company access road whileparking lot or company access road while
the employee is commuting to/from work.the employee is commuting to/from work.
 The illness is the common cold or flu.The illness is the common cold or flu.
 The illness is a mental illness unless aThe illness is a mental illness unless a
psychiatrist or psychologist has stated thatpsychiatrist or psychologist has stated that
the employee has a mental illness that isthe employee has a mental illness that is
work-related.work-related.

11. DefinitionDefinition
 New Case:New Case:
– The employee has not previously experienced aThe employee has not previously experienced a
recorded injury/illness of the same type that affects therecorded injury/illness of the same type that affects the
same body part, orsame body part, or
– The employee previously experienced a recordedThe employee previously experienced a recorded
injury/illness of the same type that affected the sameinjury/illness of the same type that affected the same
part of the body but had recovered completely from thepart of the body but had recovered completely from the
previous injury/illness and an event or exposure in theprevious injury/illness and an event or exposure in the
work environment caused the signs or symptoms towork environment caused the signs or symptoms to
reappearreappear

12. New Case ClarificationNew Case Clarification
 For occupational illnesses where the signsFor occupational illnesses where the signs
or symptoms may recur or continue in theor symptoms may recur or continue in the
absence of an exposure, the case must onlyabsence of an exposure, the case must only
be recorded once.be recorded once.
 The episode is a new case if the symptomsThe episode is a new case if the symptoms
(e.g., occupational asthma) are the result of(e.g., occupational asthma) are the result of
an event or exposurean event or exposure

13. DefinitionDefinition
 Medical Treatment:Medical Treatment: The management & care ofThe management & care of
a patient to combat disease or disorder.a patient to combat disease or disorder.
 Does not include:Does not include:
– Visits to a physician solely for observation orVisits to a physician solely for observation or
counselingcounseling
– Diagnostic procedures such as x-rays or blood tests,Diagnostic procedures such as x-rays or blood tests,
including the administration of prescriptionincluding the administration of prescription
medications used solely for diagnostic purposes (e.g.,medications used solely for diagnostic purposes (e.g.,
eye drops to dilate pupils).eye drops to dilate pupils).
– First Aid TreatmentFirst Aid Treatment

14. DefinitionDefinition
 First Aid:First Aid:
– Using a nonprescription medication at nonprescriptionUsing a nonprescription medication at nonprescription
strengthstrength
– Administering tetanus immunizations (otherAdministering tetanus immunizations (other
immunizations such as Hepatitis B vaccine areimmunizations such as Hepatitis B vaccine are
considered medical treatment)considered medical treatment)
– Cleaning, flushing or soaking wounds on the surface ofCleaning, flushing or soaking wounds on the surface of
the skinthe skin
– Using wound coverings such as bandages, Band-Aids,Using wound coverings such as bandages, Band-Aids,
gauze pads, butterfly bandages, or Steri Strips (sutures,gauze pads, butterfly bandages, or Steri Strips (sutures,
staples, etc are considered medical treatment)staples, etc are considered medical treatment)

15. Definition Continued:Definition Continued:
 Using hot or cold therapyUsing hot or cold therapy
 Using any non-rigid means of support, such asUsing any non-rigid means of support, such as
elastic bandages, wraps, non-rigid back beltselastic bandages, wraps, non-rigid back belts
(devices with rigid stays are considered medical(devices with rigid stays are considered medical
treatment)treatment)
 Using temporary immobilization devices whileUsing temporary immobilization devices while
transporting an accident victimtransporting an accident victim
 Drilling of a fingernail or toenail to relieveDrilling of a fingernail or toenail to relieve
pressure, or draining fluid from a blisterpressure, or draining fluid from a blister
 Using eye patchesUsing eye patches

16. Definition Continued:Definition Continued:
 Removing foreign bodies from the eye using onlyRemoving foreign bodies from the eye using only
irrigation or a cotton swabirrigation or a cotton swab
 Removing splinters or foreign material from areasRemoving splinters or foreign material from areas
other than the eye by irrigation, tweezers, cottonother than the eye by irrigation, tweezers, cotton
swabs, etc.swabs, etc.
 Using finger guardsUsing finger guards
 Using massages (physical therapy or chiropracticUsing massages (physical therapy or chiropractic
treatment are considered medical treatment)treatment are considered medical treatment)
 Drinking fluids for relief of heat stressDrinking fluids for relief of heat stress

17. DefinitionDefinition
 Pre-existing Conditions:Pre-existing Conditions: An injury/illnessAn injury/illness
is a pre-existing condition if it resultedis a pre-existing condition if it resulted
solely from a non-work-related event orsolely from a non-work-related event or
exposure that occurred outside the workexposure that occurred outside the work
environmentenvironment

18. More RecordablesMore Recordables
 A pre-existing injury/illness should be recorded ifA pre-existing injury/illness should be recorded if
it is significantly aggravated when anit is significantly aggravated when an
event/exposure in the work environment results inevent/exposure in the work environment results in
any of the following:any of the following:
– Death, provided that the pre-existing injury/illnessDeath, provided that the pre-existing injury/illness
would likely not have resulted in death but for thewould likely not have resulted in death but for the
occupational event or exposureoccupational event or exposure
– Loss of consciousnessLoss of consciousness
– One or more days away from work, or days ofOne or more days away from work, or days of
restricted work, or days of job transferrestricted work, or days of job transfer
– Medical Treatment if not needed before the workplaceMedical Treatment if not needed before the workplace
event or exposureevent or exposure

19. TravelTravel
 Injuries or Illnesses that occur while anInjuries or Illnesses that occur while an
employee is on travel status are work-employee is on travel status are work-
related if, at the time of the injury/illness,related if, at the time of the injury/illness,
the employee was engaged in workthe employee was engaged in work
activities “in the interest of the employer.”activities “in the interest of the employer.”
– Examples include: travel to/from customerExamples include: travel to/from customer
contacts, entertaining or being entertained tocontacts, entertaining or being entertained to
transact, discuss, or promote business, seminarstransact, discuss, or promote business, seminars
or conferencesor conferences

20. Travel ClarificationTravel Clarification
 Not work related when:Not work related when:
– Employee is checking into a hotel, motel, orEmployee is checking into a hotel, motel, or
other temporary residenceother temporary residence
– Employee is on a personal detour from aEmployee is on a personal detour from a
reasonably direct route of travel (e.g., has takenreasonably direct route of travel (e.g., has taken
a side trip for personal reasons)a side trip for personal reasons)

21. Working at HomeWorking at Home
 Injuries/Illnesses that occur while anInjuries/Illnesses that occur while an
employee is working at home will beemployee is working at home will be
considered work-related if the injury/illnessconsidered work-related if the injury/illness
occurs while the employee is performingoccurs while the employee is performing
work for pay or compensation in the home,work for pay or compensation in the home,
and the injury/illness is directly related toand the injury/illness is directly related to
the performance of work rather than to thethe performance of work rather than to the
general home environment or setting.general home environment or setting.

22. New RecordablesNew Recordables
 Tuberculosis if evidenced by a positive skin test orTuberculosis if evidenced by a positive skin test or
diagnosed by a physiciandiagnosed by a physician
 Medical Removal – Employee is removed from aMedical Removal – Employee is removed from a
their position under a medical removal provisiontheir position under a medical removal provision
in Title 8 regardless of the presence of diagnosisin Title 8 regardless of the presence of diagnosis
of an injury/illness. Must be recorded as daysof an injury/illness. Must be recorded as days
away from work or restricted work activity. Useaway from work or restricted work activity. Use
column “poisoning” (e.g., benzene, cadmium,column “poisoning” (e.g., benzene, cadmium,
methylene chloride, lead, formaldehyde)methylene chloride, lead, formaldehyde)

23. New Recordables ContinuedNew Recordables Continued
 Needlestick and Sharps InjuriesNeedlestick and Sharps Injuries
– All work-related needlestick injuries and cuts fromAll work-related needlestick injuries and cuts from
sharp objects that are contaminated with anothersharp objects that are contaminated with another
person’s blood or other potentially infectious materialperson’s blood or other potentially infectious material
should be entered as an injury. To protect privacy,should be entered as an injury. To protect privacy,
employee’s name may not be entered on OSHA 300 logemployee’s name may not be entered on OSHA 300 log
instead enter “privacy case.”instead enter “privacy case.”
– If employee is diagnosed with an infectious bloodborneIf employee is diagnosed with an infectious bloodborne
disease, update description and change classificationdisease, update description and change classification
from an injury to an illnessfrom an injury to an illness
– If employee is splashed with blood or OPIM, record ifIf employee is splashed with blood or OPIM, record if
it results in a bloodborne illnessit results in a bloodborne illness

24. DefinitionDefinition
 Privacy Concern Case:Privacy Concern Case:
– Injury/illness to an intimate body part or theInjury/illness to an intimate body part or the
reproductive systemreproductive system
– Injury/illness resulting from a sexual assaultInjury/illness resulting from a sexual assault
– Mental illnessesMental illnesses
– HIV Infection, hepatitis, or tuberculosisHIV Infection, hepatitis, or tuberculosis
– Needlestick injuries and cuts from sharp objectsNeedlestick injuries and cuts from sharp objects
– Illnesses in which an employee independentlyIllnesses in which an employee independently
and voluntarily requests that his/her name notand voluntarily requests that his/her name not
be entered on the logbe entered on the log

25. Rules for Counting Lost DaysRules for Counting Lost Days
 Count calendar days and cap at 180Count calendar days and cap at 180
 Do not include day of injuryDo not include day of injury
 Stop counting if a physician release anStop counting if a physician release an
employee to work but employee fails toemployee to work but employee fails to
show upshow up
 Special circumstances –injury beforeSpecial circumstances –injury before
vacation or weekendvacation or weekend

26. Rules for Counting RestrictedRules for Counting Restricted
Days or Transfer DaysDays or Transfer Days
 Record if employee is kept from performing oneRecord if employee is kept from performing one
or more routine dutiesor more routine duties
 Do not have to record if restriction is only for dayDo not have to record if restriction is only for day
of injuryof injury
 Recommended restrictions are only recorded ifRecommended restrictions are only recorded if
employee is kept from performing one or moreemployee is kept from performing one or more
routine job dutiesroutine job duties
 A partial shift because of an injury is counted as aA partial shift because of an injury is counted as a
day of restrictionday of restriction
 Stop counting if employee’s job has beenStop counting if employee’s job has been
permanently modified or changedpermanently modified or changed
 Count calendar days and cap at 180Count calendar days and cap at 180

27. 3.0 Maintenance & Retention of3.0 Maintenance & Retention of
RecordsRecords
 Each department must maintain their ownEach department must maintain their own
OSHA 300s, 300As and 301s. RecordsOSHA 300s, 300As and 301s. Records
must be maintained centrally but must bemust be maintained centrally but must be
made available upon request to anymade available upon request to any
employee, former employees, authorizedemployee, former employees, authorized
employee representative, or Cal/OSHAemployee representative, or Cal/OSHA
inspector.inspector.

28. OSHA 300OSHA 300
 Recordable entries must be made withinRecordable entries must be made within
seven (7) calendar days after receivingseven (7) calendar days after receiving
information that a recordable injury/illnessinformation that a recordable injury/illness
has occurred.has occurred.
 Any changes to previous entries must alsoAny changes to previous entries must also
be made within seven (7) calendar days ofbe made within seven (7) calendar days of
dutiful knowledge of such a change.dutiful knowledge of such a change.
 The log must be kept complete and updatedThe log must be kept complete and updated
to within 45-calendar days.to within 45-calendar days.

29. OSHA 300 ContinuedOSHA 300 Continued
 All log totals must be adjusted accordinglyAll log totals must be adjusted accordingly
to reflect any changes.to reflect any changes.
 Must be retained for 5 years and must beMust be retained for 5 years and must be
updated to include newly discoveredupdated to include newly discovered
recordable injuries/illnesses and anyrecordable injuries/illnesses and any
changes in classification of injury/illnesschanges in classification of injury/illness
 Send to City Safety Office at theSend to City Safety Office at the
beginning of each monthbeginning of each month

30. OSHA 300AOSHA 300A
 Total columns G – M on OSHA 300 andTotal columns G – M on OSHA 300 and
transfer to 300A at the end of the calendartransfer to 300A at the end of the calendar
yearyear
 Does not have to be updated during 5 yearDoes not have to be updated during 5 year
storagestorage
 Must be signed by City Safety Officer, CityMust be signed by City Safety Officer, City
Manager, Assistant City Manager, orManager, Assistant City Manager, or
Deputy City ManagerDeputy City Manager

31. OSHA 301OSHA 301
 Departments must complete and file thisDepartments must complete and file this
form within seven (7) calendar days ofform within seven (7) calendar days of
receipt of information on a recordablereceipt of information on a recordable
injury or illnessinjury or illness
 May use 5020 in lieu of 301May use 5020 in lieu of 301
 Must be retained for five (5) yearsMust be retained for five (5) years

32. 4.0 Posting Requirements4.0 Posting Requirements
 Only Form 300A is postedOnly Form 300A is posted
WHY:WHY: Employee right to informationEmployee right to information
WHERE:WHERE: Conspicuous place or places whereConspicuous place or places where
employee notices are customarily postedemployee notices are customarily posted
WHEN:WHEN: From February 1 to April 30From February 1 to April 30

33. Target DatesTarget Dates
 Begin logging injuries/illnesses on 300 LogBegin logging injuries/illnesses on 300 Log
starting January 1starting January 1
 Use OSHA 200 Log for calendar year 2001Use OSHA 200 Log for calendar year 2001

34. The EndThe End
 QuestionsQuestions
 ExerciseExercise
 Thank you forThank you for
attending!attending!