1. OSHA Recordkeeping ( OSHA 29 CFR 1904 )
Presented by Sheakley UniService, Inc.
Sheakley’s Health and Safety Services

2. Objectives / Outcomes
Discuss why injury & illness records are important
Determine if standard applies to your place of employment
Review standard revisions on severe injury reporting requirements
Explain the most recent addition to the rule for online reporting
Differentiate between recordable and non-recordable cases
Review OSHA Recordkeeping requirements and forms: 300, 301, and 300A
Introduce administrative solutions

3. Why keep injury-illness records?
Captures data on how people get hurt
Helps identify problem areas / trends
Helps prevent future injury or illness
More effective safety program
Increase employee safety awareness
It may be a Federal requirement within your facility
200,000 BLS surveys are mailed each year

4. Occupational Safety and Health Administration
Vs.
U.S. Department of Labor
Occupational Safety and Health Administration
A common misconception is that if it is a workers’ comp injury then it is also an OSHA recordable injury
OSHA Recordkeeping and the BWC processes are independent of each other.
A rule of thumb is:
All OSHA recordable injuries are workers’ comp claims
Not all workers’ comp injuries are OSHA recordable

5. Key Elements
Employers with 10 or fewer employees (includes temporary employees) are exempt from recordkeeping requirements
Currently all employers must report fatalities in 8 hours to OSHA. As of January 2015, in addition to notifying OSHA of fatalities, you must also call them within 24 hours of finding out about them:
All work-related amputations
All work-related losses of an eye
All work-related in-patient hospitalizations of one or more employees
To report an incident:
Call OSHA
Call your nearest OSHA area office
Visit

6. When must I contact OSHA?
Prior to January 2015, employers reported fatalities in 8 hours to OSHA. In addition to notifying OSHA of fatalities, you now must also call them within 24 hours of the below occurrences:
All work-related amputations
Loss of a limb or other external body part
Includes: A part, such as a limb or appendage, that has been severed, cut off, amputated (completely or partially); fingertip amputations with or without bone loss; medical amputations from irreparable damage
All work-related losses of an eye
Loss of entire eyeball
Does not relate to vision
All work-related in-patient hospitalizations of one or more employees
Defined as a formal admission to the inpatient services of a hospital or clinic for care or treatment
Inpatient admission for diagnostic testing or observation does not apply
Non-prescription drug dosages are considered:
467 mg or less of Ibuprofen (ADVIL / MOTRIN)
50 mg or less of Diphenhydramine (antihistamine in BENADRYL)
220 mg or less of Naproxen (ALEVE)

7. News Just In …
Prior to OSHA’s severe injury/ illness reporting rule has come to confirm:
All work-related amputations
2,644 amputations were reported
Primarily manufacturing
All work-related losses of an eye
No data statistics calculated
All work-related in-patient hospitalizations of one or more employees
7,636 in-patient hospitalizations were reported
Primarily manufacturing and construction
Non-prescription drug dosages are considered:
467 mg or less of Ibuprofen (ADVIL / MOTRIN)
50 mg or less of Diphenhydramine (antihistamine in BENADRYL)
220 mg or less of Naproxen (ALEVE)

8. News Just In …
Prior to OSHA’s severe injury/ illness reporting rule has come to confirm:
Top 5 industry groups to report severe injuries
1 – Structure/ foundation contractors, 2 – Building equipment contractors, 3 – Mining operations, 4 – Commercial building construction and 5 – Postal services
Reporting lead to very productive inspections
One-third of all severe injury/ illness reports led in wall-to-wall investigations
58% of amputations reported resulted in investigations
OSHA believes that 50% or more severe injury/ illnesses are not being reported
Found through state funded programs and self-insurers loss run reports
Majority of severe reports were filed by large sized employers
OSHA is working through insurer’s and first responders to help educate small to mid-sized employers
Non-prescription drug dosages are considered:
467 mg or less of Ibuprofen (ADVIL / MOTRIN)
50 mg or less of Diphenhydramine (antihistamine in BENADRYL)
220 mg or less of Naproxen (ALEVE)

9. Online Reporting Rule
Effective January 1, 2017 (State Plans have until 7/1/2017)
WHO?
Certain industries and certain sized employers must comply:
High-risk industries WITH employees (Construction, transportation, utilities, warehousing, waste management, residential care facilities, commercial machinery/ equipment maintenance, wholesale trades, building materials, etc.)
All industries with greater than 250 employees
Employers with multiple locations – must calculate the total of all combined however online reporting will be location specific
HOW?
OSHA will provide a secure website with a unique PIN for entry, 3 ways can occur:
Manually enter data via site using fillable PDF format
Electronically upload information via the attachment of a CSV file (X-cel)
Electronic interfacing application
Non-prescription drug dosages are considered:
467 mg or less of Ibuprofen (ADVIL / MOTRIN)
50 mg or less of Diphenhydramine (antihistamine in BENADRYL)
220 mg or less of Naproxen (ALEVE)

10. Online Reporting Rule WHEN?
Dates and forms for compliance are staged as such:
WHY?
OSHA has implemented this online reporting rule for various reasons:
Allows them to review trends for enforcement and aid in safety initiative programs
Allows for job-seekers, customers, and investors to review injury/illness history
Allows the Dept. of Labor to create more accurate industry injury rates
Submission Year
EOR with EE
EOR with EE
Deadline
(will be 2016 records)
300A form
July 1, 2017
(will be 2017 records)
300, 300A, 301 forms
July 1, 2018
forward (will be 2018 records)
March 2nd
Non-prescription drug dosages are considered:
467 mg or less of Ibuprofen (ADVIL / MOTRIN)
50 mg or less of Diphenhydramine (antihistamine in BENADRYL)
220 mg or less of Naproxen (ALEVE)

11. Online Reporting Rule ADDITIONAL DETAILS:
All data that is entered online will be visible to the general public however employee name and treating physician identities will be private
While online recording still excludes many small to mid-sized establishments and lower risk industries, OSHA recordkeeping forms must still be maintained internally if applicable.
While online recording applies to larger and high risk industries, these employers must still maintain and track recordkeeping forms internally.
Non-prescription drug dosages are considered:
467 mg or less of Ibuprofen (ADVIL / MOTRIN)
50 mg or less of Diphenhydramine (antihistamine in BENADRYL)
220 mg or less of Naproxen (ALEVE)

12. What is a recordable injury?
Injuries involving:
Death (Must report to OSHA within 8 hours)
Days away from work
Restricted work or transfer to another job
Medical treatment beyond first aid
Physical therapy / Chiropractic treatments
Loss of consciousness
Written prescriptions (dosage will make final determination)
Ibuprofen (such as Advil™) - Greater than 467 mg
Diphenhydramine (such as Benadryl™) - Greater than 50 mg
Naproxen Sodium (such as Aleve™) - Greater than 220 mg
Standard Threshold Shift in hearing in one / both ears
A significant injury or illness diagnosed by a physician or other health care professional
Licensed physician recommends medical treatment but employee refuses, it is still recordable
Non-prescription drug dosages are considered:
467 mg or less of Ibuprofen (ADVIL / MOTRIN)
50 mg or less of Diphenhydramine (antihistamine in BENADRYL)
220 mg or less of Naproxen (ALEVE)

13. What is not a recordable injury?
Injuries involving:
An employee injured while acting in part of the general public
Eating, drinking, preparing food for personal consumption
Personal tasks at the establishment outside of work hour
Personal: Grooming, Self-medication
Voluntary participation in: Wellness programs, Med fitness, Recreational activity
Motor vehicle accident on company lot during commute
Common cold or flu
Mental illness
Employee performing work for pay in the home and injury is due from home environment
First Aid procedures are applied
Employee in travel status….
Checked into hotel (home away from home )
Commute to job location NOT RECORDABLE
Detour for personal reasons NOT RECORDABLE
Leave for food consumption NOT RECORDABLE
The emphasis here is on voluntary, if you require participation then yes it is recordable. As contrasted with “ they are they to pick up there check” – in which this case they are required to pick it up and they are not considered member of the public.

14. First Aid - General Rule
Injury that does not require more than first aid treatment is usually not recordable…
So what is considered First Aid?
Using a non-prescription medication at non-prescription strength
Diagnostic procedures – x-ray, blood tests
Administering tetanus immunizations
Cleaning, flushing or soaking wounds on the skins surface
Using wound coverings such as bandages, gauze or butterfly bandages – Stitches will be recordable as well as surgical glue
Using hot or cold therapy
Using a non-rigid means of support, such as: wraps, elastic bandages, non rigid back belts, etc.
Drilling of a fingernail or toenail to relieve pressure
Utilization of an eye patch
Removing a foreign body from the eye using ONLY irrigation or cotton swab
Use of a finger guard, use of massages and drinking fluids for heat stress relief

15. OSHA Recordkeeping Forms
300 LOG
Use to list all the recordable injuries and illnesses in your workplace within 7 days
Use as a tool for detecting problems and trends within your workplace
Requires updates to be noted once exact counts are known
300A SUMMARY
Injury and illness information will total and rollover onto this form
This form must be posted each year from Feb 1 – April 30
Once posted this summary does not require updates to be noted
301 FORM
Use to record details about a recordable incident within 7 days
You may use an equivalent form to replace this 301 – example: BWC FROI

16. 300

17. 300 A
If you download your OSHA Recordkeeping workbook from the OSHA.gov website all the data entered on the 300 log will calculate to roll over onto the 300 A summary sheet. You will however have to calculate total hours worked as well as your NAIS/ SIC Code. Temp workers hours are figured into the annual worked hours HOWEVER, they do not get counted as part of the employee total for the year. Refer them to OSHA.gov and MANTA.com website for SIC code. The Company Executive is only required to sign.

18. 301
This form may be replaced by the Ohio BWC’s First Report of Injury Form the FROI as it includes equivalent data. This form as well as the prior 2 may all be kept electronically. My experience with OSHA audits has been that they have reviewed the 300 and the 300 A, it does not appear that part of the audit is to review the 301 sheets?.

19. “Privacy Case”
To protect injured employee’s privacy when forms are released – what is considered to be a private case?
Intimate body part or reproductive system
Sexual assault
Mental illness
HIV infection, hepatitis or tuberculosis
Needle stick/ sharps injuries
(Record as an injury initially, however if the employee is later
diagnosed with an infectious bloodborne disease, then update the log to an illness.
Even if you are covered by HIPAA, disclosing OHSA 300s containing employee PHI shouldn't get you into trouble. That's because there are exceptions within HIPAA when you're allowed to disclose PHI about individuals even without their permission. One of these exceptions is when disclosure is "required by law."

20. Facts & Statistics Industry with the highest incident rate:
Officers per each million employees
Industry with the highest incident rate:
Animal slaughtering
(300 injuries per 10K staff)
1/3 of all severe injury reports have initiated inspections
U.S. workers are dying every 2 hours
Inspections will result in wall-to-wall inspections
2014 – 184 Ohio fatalities occurred
(168 men, 16 women)
2015
OSHA received 8,700 severe injury reports
1970 OSHA had 36 Officers per each million employees

21. Sheakley Health & Safety Services Jillian Santel 800-877-5055 x
Sheakley Health & Safety Services Jillian Santel x