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					Recordkeeping & Reporting: How the Revised Standard Affects Industry
Presented by: Angela K. Fineis (ATC Associates Inc.)

History of the Regulations
In place since 1971 Proposed changes announced in February 1996 (“The Revision of the Injury & Illness Recordkeeping System”) Revision announced on January 18, 2001 Final rule published in Federal Register on January 19, 2001 Final rule effective January 1, 2002

What are the regulatory requirements?
OSHA regulations address:
 Occupational injury and illness

recording  Occupational injury and illness reporting

Applicable regulations:
 29 CFR 1904  29 CFR 1952

What is the purpose of the regulations?
Provide employers with a tool for tracking and recording workplace illnesses and injuries Aid employers with recognizing workplace hazards and correcting hazardous conditions Allow OSHA to track trends in safety

What prompted revisions to the regulations?
Industry complaints
 Former recordkeeping requirements were

complicated  Former recordkeeping forms were cumbersome

Confusing regulations
 Former regulations included only

requirements  Interpretations were found in many forms

What prompted revisions to the regulations? (continued)
Former regulations did not include provisions for needlestick and sharps injuries Former regulations included complicated criteria for reporting musculoskeletal disorders (MSDs) OSHA attempting to revise, update, and simplify all regulations

Who is subject to the regulations?
All employers subject to the OSH Act Exempt from most requirements: Industries classified as low-hazard sectors
 e.g., Retail, service, finance, insurance, and real estate

 List revised to reflect recent industry illness/injury data.

Excluded from full reporting requirements:
 Religious establishments  Household employees performing ordinary domestic

tasks  Certain volunteers

Who is subject to the regulations? (continued)
Excluded from full reporting requirements: (continued)
 Industries classified under SIC codes 52-809,

except codes 52-54, 70, 75, 76, 79, and 80  Small businesses (10 or less employees)  Sheltered workshops and job training programs (unless personnel are compensated)  Stockholders (unless employed by the corporation in which they hold stock)  Self-employed persons

Primary Improvements to the Standard
Better definition of work-related injuries Clarified definition of restricted work Provisions for improved employee awareness and involvement
 Provides workers or their representatives

access to the information on recordkeeping forms  Increases awareness of potential hazards in the workplace

Provisions for employee privacy

Primary Improvements to the Standard (continued)
“Plain English” wording Question and answer format Inclusion of checklists and flowcharts Inclusion of interpretations as well as requirements Simpler forms Flexibility for using computers to meet requirements

Summary of Key Provisions to New Recordkeeping Rule
Updated recordkeeping forms
 OSHA Form 300: Log of Work-related Injuries

and Illnesses

 Replaces Form 200: Log and Summary of

Occupational Injuries & Illnesses  Simplified reporting requirements  Printed on smaller legal sized paper

Summary of Key Provisions to New Recordkeeping Rule (continued)
Updated recordkeeping forms (continued)
 OSHA Form 301: Injury and Illness Incident

Report

 Replaces Form 101: Supplementary Record of

Occupational Injuries & Illnesses  Includes more data about how injury or illness occurred

 OSHA Form 300A: Summary of Work-related

Injuries and Illnesses (easier calculation of incident rates)

Summary of Key Provisions to New Recordkeeping Rule (continued)
Eliminates different criteria for recording work-related injuries and work-related illnesses
 New rule uses one set of criteria for injuries

and illnesses.  Former rule required employers to record all illnesses, regardless of severity.  New rule accounts for severity of illness.

Summary of Key Provisions to New Recordkeeping Rule (continued)
Requires records to include any workrelated injury or illness resulting in:
 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

licensed health care professional

Note: Exposures in and of themselves are not recordable.

Summary of Key Provisions to New Recordkeeping Rule (continued)
Includes new definitions to simplify recording decisions
 Medical treatment  First aid  Restricted work

Summary of Key Provisions to New Recordkeeping Rule (continued)
Requires a significant degree of workrelated aggravation before a pre-existing injury or illness becomes recordable Includes separate provisions describing recording criteria for cases involving work-related transmission of tuberculosis

Summary of Key Provisions to New Recordkeeping Rule (continued)
Add additional exemptions to the definition of work-relationship
 Limits recording of cases involving

eating/drinking food beverages  Limits recording of common colds and flu  Limits recording of blood donations  Limits recording of exercise programs  Limits recording of mental illness

Summary of Key Provisions to New Recordkeeping Rule (continued)
Clarifies recording of “light duty” or “restricted work” cases
 Requires employers to record cases when

injured/ill employee is restricted from normal duties  Defines normal duties: duties the employee performs at least once weekly

Summary of Key Provisions to New Recordkeeping Rule (continued)
Conforms with new ergonomics standard
 Requires employees to record all needlestick

and sharps injuries involving contamination by another person’s blood or body fluids  Applies same recording criteria to MSDs as to all other injuries and illnesses  Revised recordkeeping forms have separate column for recording MSDs  Employers retain flexibility to determine whether an event or exposure in work environment caused or contributed to MSD

Summary of Key Provisions to New Recordkeeping Rule (continued)
Requires employers to record standard threshold shifts (STS) in employees’ hearing
 Defines STS: an adverse change in an

employee’s hearing threshold, relative to his/her most recent audiogram  Requires recording hearing loss cases at 10 dB shift, rather than 25 dB shift  Provides a separate column on Form 300 to capture statistics on hearing loss

Summary of Key Provisions to New Recordkeeping Rule (continued)
Changes regarding lost/restricted work
 Change in terminology  Eliminates “lost workdays”  Focuses on “days away” or “days restricted or transferred”

 Includes new regulations for counting days  Rely on calendar days instead of workdays

Summary of Key Provisions to New Recordkeeping Rule (continued)
Changes to employer requirements
 Employers must establish procedure for

employees to report injuries and illnesses  Employers must tell employees how to report  Employers are prohibited from discriminating against employees who report  With change of ownership, seller must turn over OSHA records to buyer

Summary of Key Provisions to New Recordkeeping Rule (continued)
Changes to employee rights
 Privacy rights  Prohibits employers from entering an individual employee’s name on Form 300 for certain types of injuries/illnesses Sexual assaults HIV infections Mental illness

Summary of Key Provisions to New Recordkeeping Rule (continued)
Changes to employee rights (continued)
 Privacy rights  Provides employers the right not to describe the nature of sensitive injuries where the employee’s identity would be known  Gives employee access to portions of Form 301 relevant to the employee they represent  Requires employers to remove employees’ names before providing data to persons not provided access under the rule

Summary of Key Provisions to New Recordkeeping Rule (continued)
Requires the annual summary to be posted for three months (Feb. 1 to April 30) instead of one Requires certification of annual summary by a company executive Changes reporting of fatalities and catastrophes to exclude some motor carrier and motor vehicle incidents Allows all forms to be kept on computer equipment or at alternate location

General Impact of Changes
Final rule anticipated to impact approximately 1.3 million establishments
 Some changes will increase number of

recordable cases; some will decrease number  OSHA anticipates roughly same number of reported injuries/illnesses

Newly exempt industries will experience reduced costs

General Impact of Changes (continued)
Newly covered industries will experience additional costs and benefits
 Must learn new requirements  Must revise computer systems used for

recordkeeping

Areas of Potential Cost Savings
Form 300: Less time to complete simpler forms Exemptions from the requirement to consider certain cases work-related (will result in less cases being recorded) Elimination of different recording criteria for injuries and illnesses (will result in less cases being recorded)

Areas of Potential Cost Savings (continued)
Changes to the requirements for recording illnesses and injuries with days away or job restriction/job transfer (will result in less cases being recorded) Changes to the criteria for recording cases of tuberculosis (will result in less cases being recorded) Changes to the criteria for recording fatality/catastrophe incidents (will result in less cases being recorded)

Areas of Potential Cost Savings (continued)
Elimination of separate recording criteria for MSDs (will result in less cases being recorded) Improvement in determining recordability of illness/injury Allowance of computerized and centralized records

Areas of Potential Cost Increases
Form 300A
 Requires increased employer review of data

and additional data on the average employment/hours worked at establishment  Changes result in higher quality data, but more time and cost to employer

Changes to the definitions of medical treatment and first aid (will result in more cases being recorded)

Areas of Potential Cost Increases (continued)
Change to the criteria for recording cases of hearing loss (will result in more cases being recorded) Change to the criteria for recording needlestick and sharps injury (will result in more cases being recorded) Increased employee involvement Employee privacy protections

Benefits of the Revised Regulations
More accurate data regarding occupational illnesses and injuries Simplified overall recordkeeping systems for employers Better protection for employees’ privacy
“The revision… will not lessen an employer’s recordkeeping responsibilities, but it will make it easier to successfully meet the requirements.” — Sec. of Labor, Alexis Herman

Resources for Additional Information
 Web site: www.osha.gov  OSHA Region IV (Alabama, Florida, Georgia, Mississippi): 404-562-2300  29 CFR 1904: Occupational Injury and Illness Recording and Reporting Requirements  “The Blue Book”: Recordkeeping Guidelines for Occupational Injuries and Illnesses
 Available from OSHA  Last updated in 1991


				
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