1 Brief Overview of OSHA’s Recordkeeping Rule Courtney W. Bohannon Jackson Area Office

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Brief Overview of OSHA’s Recordkeeping Rule

Courtney W. Bohannon

Jackson Area Office

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1904.5 – Work-Relatedness• A case is considered work-related if an event or

exposure in the work environment either caused or contributed to the resulting condition

• A case is considered work-related if an event or exposure in the work environment significantly aggravated a pre-existing injury or illness

• Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment

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1904.5 – Work Environment• The work environment is defined as the

establishment and other locations where one or more employees are working or present as a condition of employment

• The work environment includes not only physical locations, but also the equipment or materials used by employees during the course of their work

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Requires records to include any work-related injury or illness resulting in one of the following; Death; Days away from work; Restricted work; Medical treatment;

Recordkeeping Highlights

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Recordability (cont’d): Loss of consciousness; Diagnosis of a

significant injury/illness

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1904.7(b)(4)Restricted Work

• Restricted work activity occurs when:– An employee is kept from performing one or

more routine functions (work activities the employee regularly performs at least once per week) of his or her job; or

– An employee is kept from working a full workday; or

– A PLHCP recommends either of the above

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1904.7(b)(4) – Job Transfer• 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

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1904.7(b)(5) – First Aid• Using nonprescription medication at

nonprescription strength• Tetanus immunizations• Cleaning, flushing, or soaking surface

wounds• Wound coverings, butterfly bandages, Steri-

Strips• Hot or cold therapy• Non-rigid means of support• Temporary immobilization device used to

transport accident victims

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1904.7(b)(5) – First Aid• Drilling of fingernail or toenail, draining fluid

from blister• Eye patches• Removing foreign bodies from eye using

irrigation or cotton swab• Removing splinters or foreign material from areas

other than the eye by irrigation, tweezers, cotton swabs or other simple means

• Finger guards• Massages• Drinking fluids for relief of heat stress

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To records or not record?

• Second or subsequent hot and cold soaks and use of whirlpool treatment.

• Not Recordable

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• One-time administration of oxygen for several minutes.

• Recordable

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• Employee has work-related elbow pain and is given non-prescription pain medication at prescription strength.

• Recordable

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• Adds additional exemptions to the definition of work-relationship.

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• Requires recording of all needlestick and sharps injuries involving contamination by another person's blood or other bodily fluids.

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Provisions describing the recording criteria for cases involving the work-related transmission of tuberculosis or medical removal under OSHA standards.

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Recordkeeping Highlights Eliminates the

term "lost workdays" and focuses on days away or days restricted or transferred.

Cap day count at 180 days.

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Establish a procedure for employees to report injuries and illnesses and tell their employees how to report.

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Protects employee privacy

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Updates the three recordkeeping forms: OSHA form 300 OSHA form 301 OSHA form 300A

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• 3 month posting.

• Certify.

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• Changes the reporting of fatalities and catastrophes to exclude some motor carrier and motor vehicle accidents.


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Record Access Must provide limited access to injury

and illness records Must provide copies of the records

within 4 business hours Use the business hours of the

establishment where the records are located

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Electronic Version of OSHA 300 & 300A

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Electronic Version of OSHA 300 & 300A

If you would like a copy, e-mail me at: [email protected] Type “e-300” in subject line

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Activity #2: Entering Information

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Entering Information on the OSHA 300 Log

• 1/23/02, Allen Ghouleah, Welder in Welding Department, developed flash burn in both eyes. Received prescription medication. No days away from work.

• Recordable {1904.7(b)(5)}, Other Recordable Cases, All other illnesses.

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• 2/1/02, Shawn Hogal, Maintenance Supervisor in Maintenance Department working in the boiler room. Found unconscious in boiler. Sent to hospital where he died 2/3/02. Diagnosis was death due to carbon monoxide.

• Recordable, Death, Poisoning.

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• 3/6/02, Bob Foglia, Shipping Department Forklift Operator. Broke his right large toe, when the forklift ran over his foot. Unable to walk but was able to drive the forklift. Had another employee do work for him which required walking for 4 days. No days away from work.

• Recordable, Job Restriction, Injury (4 days job restriction)

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• 3/9/02, Marilyn Rose, Canning Machine Operator in Canning Department. Foreign object in right eye (not embedded). Doctor said she could return to work but Marilyn did not return for 2 days because of eye pain.

• Not Recordable

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• 3/11/02 Carrie Nation, Maintenance Department. Employee is designated first aid responder reported that she received a needle stick to the left hand while cleaning up the Canning Area contaminated with Mark Boulware’s blood after the EMS team removed Mark. There was a recommendation for medical treatment.

• Recordable, Other recordable cases, Injury-Privacy Case.

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• 6/21/02 Cathy Withmore, Computer Operator in the Training Department, choked on a sandwich in the lunchroom. Hospitalized for 2 days.

• Not Recordable {1904.5(b)(2)(iv)}.

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• 7/15/02 Valerie Gilmore, retired Boiler Room Supervisor (4 years ago), after working 40 years. She was diagnosed with work related asbestosis.

• Recordable, Other Recordable Cases, Respiratory Condition.

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• 7/16/02 John Doe, Shop Foreman, had a diabetic incident that occurred while he was working.

• Not Recordable {1904.5(b)(2)(ii)}.

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Courtney W. BohannonUSDOL – OSHAJackson Area Office

3780 I-55 North Suite 210Jackson, MS 39211-6323601-965-4606 ext. 35

[email protected]

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DISCLAIMERThis information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address recordkeeping, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute,

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DISCLAIMERregulations, and standards. Likewise, to the extent

that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new

technology, information, or circumstances; to keep apprised of such developments, or to review

information on a wide range of occupational safety and health topics, you can visit OSHA’s website at

www.osha.gov

Documents

1 Brief Overview of OSHA’s Recordkeeping Rule Courtney W. Bohannon Jackson Area Office