Injury/Illness Recordkeeping & Reporting - OSHA 300 Recordkeepign by WV5W2f


									                  Injury/Illness Recording &
               OSHA 300 Recordkeeping Requirements

August, 2011
                        Topics Covered
This presentation is an outline of the requirements
of injury/illness recordkeeping and will cover the
following topics:
        What is injury/illness recordkeeping?

        Who has to keep these records?

        What is considered a workplace injury?
        What information must be recorded?

        What are the forms you need to fill out?

Note: DOSH injury/illness recordkeeping requirements are similar but
not identical to federal OSHA injury/illness recordkeeping requirements.
    What is injury and illness recordkeeping?

Most businesses are required by both federal OSHA and DOSH
to keep records of employee on-the-job injuries or illnesses on
the form shown above (plus two other forms discussed later.)
       Why is workplace injury & illness
            recording important?
It is required by DOSH regulations (WAC 296-27),
but it can also do the following for employers:

- capture information on how workers are hurt,

- help identify safety and health hazards,

- help prevent future injuries or illnesses,

- increase employee safety awareness,

- reduce worker compensation claims costs.
   Keeping records of workplace injuries and
          illnesses does NOT mean:

    that the employer or employee was at fault,

     that a DOSH safety & health rule has been violated,

    that the injured employee is eligible for workers'
    compensation or other benefits.

However, if a DOSH safety & health inspector visits your
workplace, they will ask if you have the records and usually
review them to determine where safety hazards may still exist.
Who must keep workplace injury/illness records?

  Many, but not all employers must keep records. However,
  certain types of businesses are exempted.*

  If not exempted, you must keep the records if you have 11
  or more employees any time during the year, including
  temporary employees.

  Applies to any employee on payroll who is injured at work.

 * Mainly retail, restaurants, service, finance, insurance and real
 estate employers – see Table 1 in the Rule. Also exempt are public
 libraries and public schools.
 What injuries/illnesses must be recorded?
Any “work-related” injury or illness:
 As defined in the Rule: “… an event or exposure in
 the work environment either caused or contributed to
 the resulting condition or significantly aggravated a
 pre-existing injury or illness.”

 Examples include cuts, fractures, back injury from lifting,
 acid splash into eyes, inhaling paint vapors that make
 existing asthma worse. Also includes fatalities.
    Reporting Fatalities and Hospitalizations
In addition to keeping records of fatalities and
serious injuries requiring a stay at a hospital,
all employers must notify L & I of these
incidents within 8 hours.

Call 1-800-423-7233 or the nearest L & I office
and provide the following:
  - time & date
 - location
 - company name
 - number of employees who died or were hospitalized
 - names of those employees
  - company contact person and phone number
  - brief description of the incident

Note: Most fatalities and many hospitalizations will be investigated by DOSH
safety & health inspectors.
   What is the “work environment”?
Definition: When employees are at a fixed workplace
establishment, they are in the work environment. When
employees are working away from the establishment, they
carry a “bubble” of work environment wherever they go.

 • Establishment and locations where one or
   more employees are working or present as a
   condition of their employment.
 • Includes all physical locations and equipment
   or materials used by the employee during the
   course of his or her work.
             Work-Related Travel Status
An injury or illness while on travel status is work-related if the
employee was engaged in work activities for the employer.

• Travel to and from customer contact

• Conducting job tasks during travel

• Business related entertainment directed by employer

• Off-time in a motel is not work-related in the
  “home away from home” concept

• Detours for personal reasons are not work-related
                        Work at Home

  Work-related injuries or illnesses at home:
 Must be performing work for pay or compensation and
 directly related to the performance of work rather than
 general home environment.
Example: If an employee drops a box of work documents and injures
her foot, or if an employee's fingernail was punctured and became
infected by a needle from a sewing machine used to perform garment
work at home, the injuries would be considered work-related.

In contrast, if an employee receives a shock and is injured due
 to faulty wiring in the home, the injury is not work related.
           Work Environment Exceptions
    Present as member of general public.
Example: If a grocery store employee is shopping after work, falls
and is injured, the employee is present as a member of the general
public and the injury is not work related.

    Symptoms arising in work environment due to
    non-work-related event or exposure.
 Example: If an employee has a pollen-caused asthma attack and
 must take medication, the disease is not work-related.

   Voluntary participation in wellness program,
   medical, fitness or recreational activity.
Example: If an employee passes out giving blood or is injured
playing basketball for a company team – the case is due to
voluntary participation in a wellness or fitness program and is not
work related.
   Cases meeting the conditions of any of these listed exceptions are not
   considered work related and do not need to be recorded.
           Work Environment Exceptions
Eating, drinking or preparing food or
drink for personal consumption.

 Example: If an employee burns his lip on a cup of coffee or
 chokes on a sandwich during lunch, the injury is not work related.

Personal tasks at the worksite but outside assigned
working hours.
Example: If an employee works on his own car in the employer’s
shop or uses the employer’s sewing machine after the shift has
ended, this is a personal task and is not work related.
Personal grooming, self medication for non-work-
related condition, or intentionally self-inflicted injury
Example: If an employee has a negative reaction to asthma medication for personal
allergies, cuts himself shaving, or commits suicide – these cases are not work
                       Work Environment Exceptions
•        Motor vehicle accident during commute.
    Example: If an employee is injured in a motor vehicle accident going to
    or leaving work at the beginning or end of shift, or for a personal errand
    – the case is not work related. However, if the employee slips on the
    ice in the company owned parking lot - the case is work related.

     •      Common cold or flu.
     Example: If an employee catches a cold or the flu, the case is not work

    •       Mental illness – unless substantiated by LHCP
            that it is work related.
     Example: Mental illness is work related only if the employee voluntarily
     provides the employer with a written opinion from a LHCP having
     appropriate qualifications and experience that affirms a work-related
     mental illness. The employer may get a second opinion and accept
     the opinion of the most qualified LHCP.
         LHCP – licensed health care professional – doctor, nurse, psychiatrist, etc.
        What must be recorded?
Record a work-related injury or illness if it results in:
 Death

 Medical treatment beyond first aid

 Loss of consciousness

 Significant injury or illness diagnosed by a licensed
  healthcare professional.

 Days away from work (off work)

 Restricted work or job transfer
What is considered medical treatment?
Management and care of a patient to combat
disease or disorder. (does not have to be treatment by a doctor)
   Does not include:

   Visits to health care provider solely for
   observation or counseling,

   Diagnostic procedures such
   as x-ray, blood tests or MRIs,

    First aid
  First Aid Actions Not Considered Medical Treatment
• Using a nonprescription medication at nonprescription strength;

• Administering tetanus immunizations (other immunizations, such as
  Hepatitis B vaccine or rabies vaccine, are considered medical treatment);

• Cleaning, flushing or soaking wounds on the surface of the skin;

• Using wound coverings such as bandages, Band-Aids™, gauze pads, etc
  (other wound closing devices such as sutures, staples, etc. are
  considered medical treatment);

• Using hot or cold therapy;

• Using any non-rigid means of support, such as elastic bandages, wraps,
  non-rigid back belts, etc. (rigid devices or other systems designed to
  immobilize parts of the body are considered medical treatment for
  recordkeeping purposes);
First Aid Not Considered Medical Treatment                           (continued)

• Using temporary immobilization devices while transporting an accident
  victim (e.g., splints, slings, neck collars, back boards, etc.).
• Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a
• Using eye patches;
• Removing foreign bodies from the eye using only irrigation or a cotton
• Removing splinters or foreign material from areas other than the eye by
  irrigation, tweezers, cotton swabs or other simple means;
• Using finger guards;
• Using massages (physical therapy or chiropractic treatment are considered
  medical treatment for recordkeeping purposes); or
• Drinking fluids for relief of heat stress.
 Note: even if first aid as described is provided by a doctor or other health care
 provider, it is not considered medical treatment and does not have to be recorded.
       Loss of Consciousness

All work-related cases involving loss of
consciousness must be recorded regardless of
the length of time the worker is unconscious.
       Significant diagnosed injuries and
                illnesses include:

• Cancer

• Chronic irreversible disease

           • Fractured or cracked bone

                    • Punctured eardrum
                      Hearing Loss

• Record as any other injury if hearing
  loss is in one or both ears and is
  related to noise exposure on the job

• Do not have to record the loss if health
  care provider determines the loss is not

• Hearing loss threshold shifts of 10
  decibels or more and 25 decibel overall
  hearing loss as detected in hearing
  tests must be recorded.
                                             Audiogram showing
                                                hearing loss
          Musculoskeletal Disorders
Record work-related injuries and illnesses
involving muscles, nerves, tendons,
ligaments, joints, cartilage and spinal discs
in the same manner that you would any
injury or illness.

Examples include such conditions as:
Carpal Tunnel Syndrome, Rotator Cuff
Syndrome, Trigger Finger, Epicondylitis,
and Low Back Pain.
       Other Specific Recording Criteria

 Needlestick and sharps injuries

 Medical removal under a DOSH safety standard


Specific requirements apply to these situations – see WAC
296-27-01109 for needlesticks, WAC 296-27-01111 for
medical removal and WAC 296-27-1115 for tuberculosis
        Significantly Aggravated Pre-Existing
                    Injury or Illness

If an employee has a pre-existing condition and an
event or exposure in the work environment aggravates
that condition and results in:
    •   death
    •   loss of consciousness
    •   medical treatment
    •   days away from work, restricted work days or job transfer,

than the injury or illness must be reported.
 Example: a worker with a minor back injury severely injures his back
 further while lifting a heavy object or a worker with a heart condition has
 a heart attack while doing heavy labor and dies.
           New Injury/Illness Cases
A case is considered new if:
• The employee has no previous recorded injury/illness
  of same type affecting the same part of the body or,
• the employee has fully recovered from previous
  injury/illness but work-related events or exposure
  caused the signs and symptoms to reappear.
                             New Cases
 Most illnesses and some injuries can
be complicated and may need medical
 • If there is a medical opinion regarding resolution of a case,
   the employer must follow that opinion.
 • If an exposure triggers the recurrence, it is a new case
   (e.g., asthma, rashes).
 • If signs and symptoms recur even in the absence of
   exposure, it is not a new case (e.g., silicosis, tuberculosis,

  Note: If two or more Physicians or Licensed Health Care Professionals
  make conflicting recommendations the employer is required to base their
  decision on the best documented and reasoned evidence.
           Days away from work cases

Criteria for entering number of days away from work:

• Do not include day of injury or illness.
• Employer must follow health care professional medical
• The number of days includes weekends, holidays,
  vacation that the employee could not work because of the
• Cap the count at 180 days.
• Stop count if employee leaves company for reason
  unrelated to injury/illness.
   Injuries requiring medical treatment, but
            no days away from work
Some minor injuries may require a visit to a medical clinic
on the day of the injury, but no time off work after that.

It is still considered a recordable injury, if actual medical
treatment occurred.

An example is a head cut requiring stitches, but the worker
returns to work the next day with no work restrictions.

Remember, x-rays, first aid or blood tests
alone do not count as medical treatment.
         Restricted Work/Job Transfer

Restricted work activity keeps employee from::
     • Performing one or more routine functions* of
       his or her job (work activities the employee
       regularly performs at least once per week) or
     • Working a normally scheduled workday.**

  *Routine functions are work activities the employee regularly
  performs at least once per week.

**The day of injury/illness is not counted as a day of restriction
             Restricted Work/Job Transfer
Restricted Work

 • Not considered restricted work if:

                Restriction limited to day of injury/illness
                Fewer goods or services produced

• Recommended restrictions from LHCP must be considered

Job Transfer
  • Assigned to job other than normal job for part of day
  • Performs normal job for part of day and assigned to another for rest
    of day
Most job transfers involve some type of restriction. Even if they don’t, job transfers due to an
injury or illness are recordable events. If an injured or ill employee is transferred to another
job for half days, this is also a job transfer.
       Restricted Work/Job Transfer

Counting days of restrictions/transfer

• Count same as days away from work.
• Stop count if permanent changes to job are made.
• If permanent changes are made the day of the
  injury/illness, the employer must count at least one
                       Privacy Cases
In some cases, names of injured employee need
to be kept private & not recorded on forms.
Privacy concern cases are limited to:
   Injury/illness to intimate body part or reproductive system
   Injury/illness resulting from sexual assault
   Mental illness
   HIV infection, hepatitis or tuberculosis
   Needle stick/sharps injuries
   Illness cases where employee requests to keep name off

 Employers may use discretion in describing a privacy
 cases to protect employee identity.
     See WAC 296-27-0119 for details
          Injury/illness recordkeeping forms
    Three Forms – OSHA 301, OSHA 300 and OSHA 300-A

These 3 forms must be used and
kept or their equivalent that records
the same information. Next slides
provide details. Click here to get full
  OSHA 301 Injury and Illness Incident Report

Must be filled out within 7 days of incident,
Must include details about an incident,
Must be retained for 5 years, and can be kept electronically,
Can use another form as long as it contains same information.
                      OSHA 300 Log

Record details within 7 days – take information from
OSHA 301 form:
–   What happened
–   Where it happened        The OSHA 300 Log must be retained
–   When it happened         for 5 years and updated if there are
                             any changes in information.
–   How it happened, and
–   Who it happened to
                 OSHA 300A Summary form

This form is a summary of all recorded incidents for a calendar
 It must be certified as accurate by company executive.
It must be posted for all employees to view from Feb. 1- April
30 of following year and kept on file for 5 years.
            Equivalent Forms

Can keep records on equivalent form if:
   Has the same information,
   Is as readable and understandable
   Completed using the same instructions as
    the OSHA form it replaces

May use computer if:
   Records can be produced when needed
   You can provide required access
Multiple Business Establishments
• Keep separate OSHA 300 for each establishment
  expected to be in business for a year or longer.

• Log may be kept at central location if you can:
   Transmit to specific worksite within four hours of request
   Meet disclosure timeframe requirements
   send information about a injury to the central location
  within 7 days of the incident

• May keep one log for several short-term
  establishments or worksites in business for less
  than one year.
            Employee Involvement

Employer must:
• Inform employee how to report injuries/illnesses
• Provide limited access to injury/illness records to
  present/past employees and their representatives:
      Authorized collective bargaining agent
       (employee rep)
      Person designated by employee (personal
      Legal representative of injured/deceased
       employee (personal representative)
      Employee Access to Records
• Employers are required to provide records to employees
  upon request.

• Provide copy of OSHA Form 300 by end of next business
  day to any employee who requests it.

• May not remove names from OSHA 300 (except privacy

• Provide copy of OSHA Form 301 to injured employee,
  former employee or personal representative by end of next
  business day upon request.
                Annual OSHA Survey

 If you receive an Annual Survey Form from
 federal OSHA you must:

      • Respond within 30 calendar days or date stated
        in survey, whichever is later
      • Respond even if normally exempt

Even though DOSH operates in Washington state, you must still respond.
    Providing Records to DOSH Inspectors
• DOSH safety & health inspectors will likely review injury &
  illness records during inspections.

• Employer must provide copies within four (4) business

• “Business hours” are determined by business hours of
  establishment where records are located.
  For more information or assistance
To speak to a DOSH staff person knowledgeable about
recordkeeping, call 360-902-5735

Do I have to maintain an OSHA 300 Log? - a short
summary of this module

How to fill out OSHA 300, 300A & 301 forms

Federal OSHA Injury Recordkeeping Rules – if you have
business locations in other states, federal rules may apply

Recordkeeping Workshops offered by DOSH staff

To top