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OSHA Recordkeeping

Revised Recordkeeping
rule effective on January
1, 2002
Affects 1.4 million
establishments




                            1
Benefits of the Rule
Improves employee involvement
Creates simpler forms
Provides clearer regulatory
requirements
Increases employers’ flexibility to use
computers


                                          2
Forms
  Updates three recordkeeping forms
     OSHA Form 300 – Log of Work-Related
      Injuries and Illnesses
     OSHA Form 301 – Injury and Illness
      Incident Report
     OSHA Form 300A – Summary of Work-
      Related Injuries and Illnesses


1904.29                                     3
OSHA Form 300   4
OSHA Form 301   5
6
Recording Criteria
  Eliminates different criteria for recording
  work-related injuries and work-related
  illnesses
  Former rule required employers to
  record all illnesses, regardless of
  severity


1904.4
                                            7
Recording Criteria Decision Tree
                                   NO    Did the employee experience an
                                                  injury or illness?

                                                                 YES


                                        NO             Is the injury or
                                                   illness work-related?

                                                                 YES

                                                                                     NO       Update the previously
                                                         Is the injury                      recorded injury or illness
                                                  or illness a new case?                        entry if necessary.
                                                                 YES



                              NO              Does the injury or illness meet
                                              the general recording criteria              YES
                                             or the application to specific cases?




         Do not record the                                                                            Record the
          injury or illness                                                                        injury or illness




1904.4                                                                                                                   8
Work-Relatedness
  Cases are work-related if:
    An event or exposure in the work
     environment either caused or contributed
     to the resulting condition
    An event or exposure in the work
     environment significantly aggravated a
     pre-existing injury or illness


1904.5                                          9
Work-Relatedness
Work-relatedness is presumed for injuries
and illnesses resulting from events or
exposures occurring in the work environment
A case is presumed work-related if, and only
if, an event or exposure in the work
environment is a discernable cause of the
injury or illness or of a significant aggravation
to a pre-existing condition. The work event or
exposure need only be one of the discernable
causes; it need not be the sole or
predominant cause
                                                10
Work-Related Exceptions
   Adds additional exceptions to the
   definition of work relationship to limit
   recording of cases involving:
     eating, drinking, or preparing food or drink
      for personal consumption
     common colds and flu
     voluntary participation in wellness or
      fitness programs
     personal grooming or self-medication


1904.5(b)(2)                                         11
General Recording Criteria
   Requires records to include any work-related
   injury or illness resulting in one of the
   following:
        Death
        Days away from work
        Restricted work or transfer to another job
        Medical treatment beyond first aid
        Loss of consciousness
        Diagnosis of a significant injury/illness by a
         physician or other licensed health care
         professional

1904.7(a)                                                 12
General Recording Criteria
                    (continued)

     Includes new definitions of medical
     treatment and first aid to simplify
     recording decisions
     Clarifies the recording of “light duty” or
     restricted work cases




1904.7(b)(5)                                      13
Recording Needlesticks
                    Requires employers to
                    record all needlestick
                    and sharps injuries
                    involving contamination
                    by another person’s
                    blood or other
                    potentially infectious
                    material


1904.8                                   14
Hearing Loss
     Starting January 1, 2003, record all work-related
     hearing loss cases where:
       Employee has experienced a Standard Threshold
        Shift (STS)1, and
       Employee’s total 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

1
  A STS is defined in OSHA’s noise standard at 29 CFR
1910.95(g)(10)(i) as a change in hearing threshold, relative
to the baseline audiogram, of an average of 10 dB or more
at 2000, 3000, and 4000 Hz in one or both ears.
    1904.10                                                  15
Musculoskeletal Disorders
Applies the same recording criteria to
musculoskeletal disorders (MSDs) as to
all other injuries and illnesses
Employer retains flexibility to determine
whether an event or exposure in the
work environment caused or
contributed to the MSD


                                        16
Tuberculosis & Medical
              Removal
   Includes separate
   provisions describing the
   recording criteria for
   cases involving the work-
   related transmission of
   tuberculosis
   Requires employers to
   record cases of medical
   removal under OSHA
   standards

1904.11 & 1904.9                 17
Day Counts

     Eliminates the term “lost workdays” and
     focuses on days away or days
     restricted or transferred
     Includes new rules for counting that rely
     on calendar days instead of workdays



1904.7(b)(3)                                 18
Employee Involvement

     Requires employers to establish a procedure
     for employees to report injuries and illnesses
     and tell their employees how to report
     Employers are prohibited from discriminating
     against employees who do report
     Employee representatives will now have
     access to those parts of the OSHA 301 form
     relevant to workplace safety and health

1904.35 & 36                                      19
Employee Privacy
    Prohibits employers from entering an
    individual’s name on Form 300 for certain
    types of injuries/illnesses
    Provides employers the right not to describe
    the nature of sensitive injuries where the
    employee’s identity would be known
    Gives employee representatives access only
    to the portion of Form 301 which contains no
    personal information
    Requires employers to remove employees’
    names before providing the data to persons
    not provided access rights under the rule
1904.29(b)                                         20
Annual Summary
 Requires the annual
 summary to be
 posted for three
 months instead of
 one
 Requires certification
 of the summary by a
 company executive


1904.32                    21
Reporting to OSHA
  Changes the reporting of fatalities and
  catastrophes to exclude some public
  transportation and motor vehicle
  accidents




1904.39                                     22

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Recordkeeping 00150 22

  • 1. OSHA Recordkeeping Revised Recordkeeping rule effective on January 1, 2002 Affects 1.4 million establishments 1
  • 2. Benefits of the Rule Improves employee involvement Creates simpler forms Provides clearer regulatory requirements Increases employers’ flexibility to use computers 2
  • 3. Forms Updates three recordkeeping forms  OSHA Form 300 – Log of Work-Related Injuries and Illnesses  OSHA Form 301 – Injury and Illness Incident Report  OSHA Form 300A – Summary of Work- Related Injuries and Illnesses 1904.29 3
  • 6. 6
  • 7. Recording Criteria Eliminates different criteria for recording work-related injuries and work-related illnesses Former rule required employers to record all illnesses, regardless of severity 1904.4 7
  • 8. Recording Criteria Decision Tree NO Did the employee experience an injury or illness? YES NO Is the injury or illness work-related? YES NO Update the previously Is the injury recorded injury or illness or illness a new case? entry if necessary. YES NO Does the injury or illness meet the general recording criteria YES or the application to specific cases? Do not record the Record the injury or illness injury or illness 1904.4 8
  • 9. Work-Relatedness Cases are work-related if:  An event or exposure in the work environment either caused or contributed to the resulting condition  An event or exposure in the work environment significantly aggravated a pre-existing injury or illness 1904.5 9
  • 10. Work-Relatedness Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment A case is presumed work-related if, and only if, an event or exposure in the work environment is a discernable cause of the injury or illness or of a significant aggravation to a pre-existing condition. The work event or exposure need only be one of the discernable causes; it need not be the sole or predominant cause 10
  • 11. Work-Related Exceptions Adds additional exceptions to the definition of work relationship to limit recording of cases involving:  eating, drinking, or preparing food or drink for personal consumption  common colds and flu  voluntary participation in wellness or fitness programs  personal grooming or self-medication 1904.5(b)(2) 11
  • 12. General Recording Criteria Requires records to include any work-related injury or illness resulting in one of the following:  Death  Days away from work  Restricted work or transfer to another job  Medical treatment beyond first aid  Loss of consciousness  Diagnosis of a significant injury/illness by a physician or other licensed health care professional 1904.7(a) 12
  • 13. General Recording Criteria (continued) Includes new definitions of medical treatment and first aid to simplify recording decisions Clarifies the recording of “light duty” or restricted work cases 1904.7(b)(5) 13
  • 14. Recording Needlesticks Requires employers to record all needlestick and sharps injuries involving contamination by another person’s blood or other potentially infectious material 1904.8 14
  • 15. Hearing Loss Starting January 1, 2003, record all work-related hearing loss cases where:  Employee has experienced a Standard Threshold Shift (STS)1, and  Employee’s total 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 1 A STS is defined in OSHA’s noise standard at 29 CFR 1910.95(g)(10)(i) as a change in hearing threshold, relative to the baseline audiogram, of an average of 10 dB or more at 2000, 3000, and 4000 Hz in one or both ears. 1904.10 15
  • 16. Musculoskeletal Disorders Applies the same recording criteria to musculoskeletal disorders (MSDs) as to all other injuries and illnesses Employer retains flexibility to determine whether an event or exposure in the work environment caused or contributed to the MSD 16
  • 17. Tuberculosis & Medical Removal Includes separate provisions describing the recording criteria for cases involving the work- related transmission of tuberculosis Requires employers to record cases of medical removal under OSHA standards 1904.11 & 1904.9 17
  • 18. Day Counts Eliminates the term “lost workdays” and focuses on days away or days restricted or transferred Includes new rules for counting that rely on calendar days instead of workdays 1904.7(b)(3) 18
  • 19. Employee Involvement Requires employers to establish a procedure for employees to report injuries and illnesses and tell their employees how to report Employers are prohibited from discriminating against employees who do report Employee representatives will now have access to those parts of the OSHA 301 form relevant to workplace safety and health 1904.35 & 36 19
  • 20. Employee Privacy Prohibits employers from entering an individual’s name on Form 300 for certain types of injuries/illnesses Provides employers the right not to describe the nature of sensitive injuries where the employee’s identity would be known Gives employee representatives access only to the portion of Form 301 which contains no personal information Requires employers to remove employees’ names before providing the data to persons not provided access rights under the rule 1904.29(b) 20
  • 21. Annual Summary Requires the annual summary to be posted for three months instead of one Requires certification of the summary by a company executive 1904.32 21
  • 22. Reporting to OSHA Changes the reporting of fatalities and catastrophes to exclude some public transportation and motor vehicle accidents 1904.39 22