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

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Highlights of OSHA’s Recordkeeping Rule

Courtney W. Bohannon

Jackson Area Office

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Recordkeeping Highlights

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

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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;


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

significant injury/illness

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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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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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Job Restriction• 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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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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• 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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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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• 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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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]

Documents

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