OSHA Injury and Illness Recordkeeping by puffdaddy

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									         OSHA
   Injury and Illness
    Recordkeeping
National Park Service Workshop
   for Recording Injuries and
  Illnesses under the New 29
     CFR1960 Requirements
 Objectives
     To provide detailed information
      about the new Federal Agency
      recordkeeping requirements
      affecting the National Park
      Service
     To explain how to make
      accurate and consistent
      recordkeeping decisions
     To answer your questions and
      address your concerns
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                    Recordkeeping Requirements
 Background
     Two different recordkeeping
      standards:
           Federal Agency – 29 CFR 1960 Subpart I
           Private Sector – 29 CFR 1904
     Standards have been significantly
      different causing confusing and
      inconsistent data
     Starting Jan. 1, 2005, the standards
      have aligned in most aspects creating
      a unified “OSHA 300 Recordkeeping
      System”

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                          Recordkeeping Requirements
 Benefits of OSHA 300 System
     Unified tracking system for all
      employers covered by OSHA,
      resulting in more accurate and
      comparable statistics between NPS
      and the private sector
     Wide variety of training, materials,
      and other resources now available to
      Federal agencies
     More accurate reflection of
      injury/illness severity
     Meets requirements for recognition
      in OSHA’s Voluntary Protection
      Program
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                     Recordkeeping Requirements
 Changes to Federal
 Recordkeeping Regulations
           29 CFR 1960 was amended to align
            federal agency injury/illness
            recordkeeping with private sector
           Except as modified, Federal
            Agencies shall comply with 29 CFR
            Part 1904, Subparts C, D, E, and G.
           Injury/Illness Recordkeeping and
            workers’ compensation are now
            independent systems

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                          Recordkeeping Requirements
 Before We Continue…

 The Federal Recordkeeping
 Regulations are now completely
 different than prior to 2005. Because
 of this:

  Forget Everything You Know or
  Think You Know About Federal
   Injury/Illness Recordkeeping.


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                   Recordkeeping Requirements
 Also…
  There   is a lot of information contained
   in this training program – You may
   refer back to this presentation and
   other materials in the OSHA
   Injury/Illness Recordkeeping Toolkit
   as needed
  In addition, the WASO and Regional
   Risk Management Offices can be
   contacted for further assistance


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                    Recordkeeping Requirements
            OSHA Recordkeeping
               Requirements

              29 CFR 1960 Subpart I
                       &
                  29 CFR 1904



1/25/2009        National Park Service Injury and Illness   8
                      Recordkeeping Requirements
 Contents
     Key Definitions
     Determination of Recordability
           Work-Relatedness
           New Cases
           General Recording Criteria
           Specific Recording Criteria
     General Recording Criteria
           Death
           Days Away/Restricted/Job Transfer
           Medical Treatment Beyond First Aid
           Loss of Consciousness
           Significant Injury/Illness diagnosed by
            PLHCP
1/25/2009             National Park Service Injury and Illness   9
                           Recordkeeping Requirements
 Contents (cont.)
     Specific Recording Criteria
           Needlestick & Sharps Injuries
           Medical Removal
           Hearing Loss
           Tuberculosis
     Privacy Concern Cases
     Recordkeeping Forms
           Form 300 – Log of Work-Related
            Injuries/Illnesses
           Form 301 – Injury and Illness Incident
            Report

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                           Recordkeeping Requirements
 Contents (cont.)
           Form 300A - Annual Summary
           Retention and Updating Records
           Providing Records to Government
            Representatives
     Other Injury/Illness Recordkeeping
      Requirements
           Multiple Establishments
           Covered Employees
           Employee Involvement
           Access to Records
           Prohibition Against Discrimination
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                           Recordkeeping Requirements
 Contents (cont.)
     Fatality & Multiple Hospitalization
      Incidents
           Incident Investigation
           Incident Notification
           Incident Summaries
     Annual OSHA Injury and Illness
      Survey
     Resources and Tips for Effective
      Recordkeeping

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                           Recordkeeping Requirements
            Key Definitions


            29 CFR 1904, Subpart G
                     and
                29 CFR 1960.2



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                     Recordkeeping Requirements
 Key Definitions

     Injury/Illness
     Reportable Injury/Illness
     Recordable Injury/Illness
     Compensable Injury/Illness
     Establishment
     PLHCP
     You

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                    Recordkeeping Requirements
 Key Definitions
 Injury/Illness
 An abnormal condition or disorder.
 Injuries result from instantaneous events.
 Examples include: a cut, fracture,
 sprain, puncture, abrasion, chipped
 tooth, insect bite, electric shock, burns,
 amputation etcetera.
 Illnesses typically result from longer term
 exposure and are broken into five
 categories: Hearing Loss; Skin Diseases
 or Disorders; Respiratory Conditions,
 Poisoning, and All Others.
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                   Recordkeeping Requirements
 Key Definitions
 Reportable Injury/Illness

 All NPS work-related employee
 injuries and illnesses are required
 to be reported and documented.
 Therefore, all work-related
 employee injuries and illnesses
 are “reportable.”



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                  Recordkeeping Requirements
 Key Definitions
 Recordable Injury/Illness

 Work-related employee injuries
 and illnesses that meet the criteria
 for inclusion on the OSHA 300 Log
 are recordable on the 300 Log and
 are therefore considered
 “recordable” cases.
     Not   all “reportable” injuries/illnesses
        are “recordable.”

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                        Recordkeeping Requirements
 Key Definitions
 Compensable Injury/Illness
 Work-related employee injuries and
 illnesses that meet the criteria for
 compensation under the Federal
 Employee’s Compensation Act (as
 administered by OWCP) are
 considered to be “compensable” cases.
     Not all “compensable” cases are
      “recordable.” They are all
      “reportable,” however

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                  Recordkeeping Requirements
 Key Definitions
 Establishment
 The term establishment means a single
 physical location where business is
 conducted or where services or
 operations are performed.
 In the NPS, an establishment typically
 refers to an independently managed
 park, office, program center, service
 center, or other independently
 managed area.

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                  Recordkeeping Requirements
 Key Definitions
 Others

 PLHCP = Physician or other Licensed
 Health Care Provider

 You = The employer (The NPS)




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                  Recordkeeping Requirements
            Determination of
             Recordability

            29 CFR 1904, Subpart C
               (1904.4 – 1904.6)




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                     Recordkeeping Requirements
 Determination of Recordability
 (1904.4)
     The following criteria must be
      met for a case to be recordable
         The employee experienced a
          work-related injury or illness, and
         The case is new, and
         The case meets one or more of
          the general or specific recording
          criteria


1/25/2009         National Park Service Injury and Illness   22
                       Recordkeeping Requirements
Determining         Injury/Illness Recordability Criteria
Recordability
                    Flowchart
                                 NO   Did the employee experience an
                                             injury or illness?

                                                       YES


                                 NO        Is the injury or illness
                                                work-related?
                                                       YES

                                                                               Update the previously
                                           Is the injury or illness   NO     recorded injury or illness
                                                 a new case?                     entry if necessary

                                                       YES

                                       Does the injury or illness meet
                                NO    the general recording criteria or    YES
                                           the additional criteria?



           Do not record the                                               Record the injury
            injury or illness                                                 or illness
            Determination of
             Recordability

            Work Relatedness
                       (1904.5)



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                    Recordkeeping Requirements
Determining
Recordability    Work-Relatedness
                     You must consider an injury/illness to be
                      work related if an event or exposure in the
                      work environment either caused or
                      contributed to the injury/illness
                     If it is not obvious whether or not the causal
                      event or exposure occurred in the work
                      environment, you must evaluate the work
                      duties and environment in which the
                      event/exposure occurred to make the
                      determination



                1/25/2009          National Park Service Injury and Illness   25
                                        Recordkeeping Requirements
Determining
Recordability    Work-Relatedness
                 The Work Environment is:
                     “The establishment and other
                      locations where one or more
                      employees are working or are
                      present as a condition of their
                      employment.”
                     “The work environment includes not
                      only physical locations, but also the
                      equipment or materials used by the
                      employee during the course of his or
                      her work.”
                1/25/2009        National Park Service Injury and Illness   26
                                      Recordkeeping Requirements
Determining
Recordability    Work-Relatedness
                 Presumption of Work-Relatedness
                     If an injury/illness results from an
                      event or exposure in the work
                      environment, work-relatedness is
                      “presumed”
                     However, an injury or illness
                      occurring in the work environment
                      that falls under one of the following
                      nine exceptions is not work-related
                      and therefore not recordable
                1/25/2009        National Park Service Injury and Illness   27
                                      Recordkeeping Requirements
Determining
Recordability    Work-Relatedness
                 Exceptions to Presumed Work-
                 Relatedness. The Injury or illness:
                   1. Occurs when the employee is
                       present in the work environment
                       as a member of the general
                       public
                   2. Results solely from voluntary
                       participation in a wellness
                       program, or in a medical, fitness,
                       or recreational activity

                1/25/2009     National Park Service Injury and Illness   28
                                   Recordkeeping Requirements
Determining
Recordability    Work-Relatedness
                 Exceptions to presumed work-
                 relatedness (cont.):
                        3.   Involves signs and symptoms
                             that surface at work, but result
                             solely from a non-work-related
                             event or exposure
                        4.   Is solely the result of an
                             employee eating, drinking, or
                             preparing food or drink for
                             personal consumption
                1/25/2009           National Park Service Injury and Illness   29
                                         Recordkeeping Requirements
Determining
Recordability    Work-Relatedness
                 Exceptions to presumed work-
                 relatedness (cont.):
                    5. Is solely the result of an
                        employee doing personal tasks
                        at the establishment outside of
                        the employee’s assigned
                        working hours
                    6. Is solely the result of personal
                        grooming, self-medication for a
                        non-work-related condition, or is
                        intentionally self-inflicted
                1/25/2009     National Park Service Injury and Illness   30
                                   Recordkeeping Requirements
Determining
Recordability    Work-Relatedness
                 Exceptions to presumed work-
                 relatedness (cont.):
                        7.   Is caused by a vehicle accident
                             and occurs on a company
                             parking lot or access road while
                             the employee is commuting
                        8.   Is the common cold or flu
                        9.   Is a mental illness (unless
                             specific situations apply)


                1/25/2009           National Park Service Injury and Illness   31
                                         Recordkeeping Requirements
Determining
Recordability    Work-Relatedness
                 Travel Status
                     If the employee was engaged in
                      work activities in the interest of
                      the NPS at the time of the
                      exposure, the resulting injury or
                      illness is considered work-
                      related


                1/25/2009       National Park Service Injury and Illness   32
                                     Recordkeeping Requirements
Determining      Work-Relatedness
Recordability
                 Three Exceptions to Work-Relatedness
                 in Travel Status
                 Injuries/illnesses are not work-related in
                 travel status if they occur while:
                   1. At the temporary lodging location
                      and not conducting official business
                      (hotel room = “home away from
                      home”)
                   2. Commuting to/from temporary
                      lodging and the job location
                   3. Taking a personal detour from the
                      direct route of business travel
                1/25/2009     National Park Service Injury and Illness   33
                                   Recordkeeping Requirements
Determining
Recordability    Work-Relatedness
                 Working At Home
                     The case is work-related if the injury
                      or illness occurs while the employee
                      is performing work for pay or
                      compensation in the home and the
                      case is directly related to the
                      performance of work rather than the
                      general home environment


                1/25/2009        National Park Service Injury and Illness   34
                                      Recordkeeping Requirements
Determining
Recordability    Work-Relatedness
                 Significant Aggravation
                     You must consider an injury or
                      illness to be work related if an event
                      or exposure in the work environment
                      significantly aggravated a non-work-
                      related pre-existing injury or illness




                1/25/2009        National Park Service Injury and Illness   35
                                      Recordkeeping Requirements
            Determination of
             Recordability

               New Cases
                        (1904.6)




1/25/2009      National Park Service Injury and Illness   36
                    Recordkeeping Requirements
Determining
Recordability    New Cases

                     In order for an injury/illness to
                      be considered recordable it
                      must be new, or a significant
                      aggravation of a pre-existing
                      non-work-related condition
                     If this is a continuation of a
                      previous work-related condition
                      – update the previous record, do
                      not create a new case

                1/25/2009      National Park Service Injury and Illness   37
                                    Recordkeeping Requirements
            Determination of
             Recordability

            General Recording
                Criteria
                         (1904.7)


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                    Recordkeeping Requirements
Determining
Recordability    General Recording Criteria

                     An injury or illness is recordable if it
                      results in one or more of the
                      following:
                           Death
                           Days away, Job Transfer or Restriction
                            (DART)
                           Medical attention beyond first aid
                           Loss of consciousness
                           Significant injury/illness diagnosed by a
                            PLHCP


                1/25/2009             National Park Service Injury and Illness   39
                                           Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Death
                     Work-related fatalities are
                      recordable
                     Record work-related fatalities by
                      entering a check mark in the
                      death column on the OSHA 300
                      Log


                1/25/2009      National Park Service Injury and Illness   40
                                    Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Days Away From Work
                     Work-related cases involving “days
                      away from work” are recordable. A
                      case is a days away from work case:
                           If the employee could not have worked
                            on any day after the injury or onset of
                            illness – whether or not there was
                            scheduled work
                           A PLHCP recommends the employee
                            stay at home but the employee comes
                            to work anyway

                1/25/2009             National Park Service Injury and Illness   41
                                           Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Days Away From Work (cont.)
                     Determine the proper number of
                      days away from work:
                         Count the number of calendar
                          days the employee was unable to
                          work regardless of the schedule
                         Begin counting from the day after
                          the injury/onset of illness
                         Cap at 180 days


                1/25/2009         National Park Service Injury and Illness   42
                                       Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Days Away From Work (cont.)

                     How do I record days away?
                         Enter the actual number of
                          calendar days in the appropriate
                          space
                         Put in an estimate whenever the
                          outcome is unknown
                         Update the system whenever new
                          information becomes available

                1/25/2009        National Park Service Injury and Illness   43
                                      Recordkeeping Requirements
Determining      General Recording Criteria
Recordability
                 Job Transfer or Restriction
                     Job transfer and restriction cases are
                      recordable
                     A “Job Restriction” occurs when,
                      because of the injury or illness, the
                      employer or a PLHCP keeps the
                      employee from performing one or
                      more of the “routine functions” of
                      their job, or from working the full
                      work day
                     A “Job Transfer” occurs when an
                      injured or ill employee is assigned to
                      a job other than his/her regular job
                1/25/2009        National Park Service Injury and Illness   44
                                      Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Job Transfer or Restriction (cont.)
                     An employee’s “routine functions”
                      are those work activities the
                      employee regularly performs at least
                      once a week.




                1/25/2009       National Park Service Injury and Illness   45
                                     Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Job Transfer or Restriction (cont.)
                 Conflicting Medical Opinions
                  If there are two different medical
                   opinions that conflict, the NPS must
                   make a decision as to which
                   recommendation is the most
                   authoritative
                  Generally, the PLHCP with more
                   knowledge and experience is the
                   most authoritative

                1/25/2009     National Park Service Injury and Illness   46
                                   Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Job Transfer or Restriction (cont.)
                     How do I record?
                         Enter the actual number of
                          calendar days in the appropriate
                          space
                         Put in an estimate whenever the
                          outcome is unknown
                         Update the system whenever new
                          information becomes available

                1/25/2009        National Park Service Injury and Illness   47
                                      Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Medical Treatment
                     If an injury/illness results in medical
                      treatment it is recordable
                     “Medical Treatment” is the
                      management and care of a patient to
                      combat disease or disorder
                     If medical treatment is
                      recommended, the case is
                      recordable even if the employee
                      does not follow the recommendation
                1/25/2009        National Park Service Injury and Illness   48
                                      Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Medical Treatment (cont.)
                     Medical treatment does not
                      include:
                         Visits to a PLHCP solely for
                          observation or counseling, or
                         The conduct of diagnostic
                          procedures, or
                         First Aid




                1/25/2009         National Park Service Injury and Illness   49
                                       Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Medical Treatment (cont.)
                     First aid treatment is first aid
                      regardless of the person
                      providing the treatment, thus the
                      most highly qualified doctor can
                      provide first aid and a lay person
                      can provide medical treatment



                1/25/2009       National Park Service Injury and Illness   50
                                     Recordkeeping Requirements
 General Recording Criteria
 First Aid
     If the only treatment provided to
      the employee is first aid, it is not
      recordable
     First aid is limited to the 14
      specific treatments listed in the
      regulation. The following list is
      all inclusive:

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                     Recordkeeping Requirements
 General Recording Criteria
 First Aid
        1.   Using a non-prescription
             medication at non-prescription
             strength
        2.   Administering Tetanus
             immunizations
        3.   Cleaning, flushing or soaking
             wounds on the surface of the skin
        4.   Using wound coverings such as
             bandages, Band-Aids™, gauze
             pads, etc., or using SteriStrips™,
             or butterfly bandages
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                         Recordkeeping Requirements
 General Recording Criteria
 First Aid (cont.)
        5.   Using hot or cold therapy
        6.   Using any totally non-rigid
             means of support, such as
             elastic bandages, wraps, non-
             rigid back belts, etc.
        7.   Using temporary immobilization
             devices while transporting an
             accident victim (splints, slings,
             neck collars, or back board).

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                         Recordkeeping Requirements
 General Recording Criteria
 First Aid (cont.)
        8.    Drilling a fingernail or toenail to
              relieve pressure, or draining fluid
              from blisters.
        9.    Using eye patches
        10.   Using simple irrigation or a
              cotton swab to remove foreign
              bodies not embedded in or
              adhered to the eye


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                          Recordkeeping Requirements
 General Recording Criteria
 First Aid (cont.)
        11.   Using irrigation, tweezers, cotton
              swab or other simple means to
              remove splinters or foreign
              material from areas other than
              the eye
        12.   Using finger guards
        13.   Using massages
        14.   Drinking fluids to relieve heat
              stress
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                          Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Loss of Consciousness (1904.7)
                     Any work-related injury or illness
                      which involves a loss of
                      consciousness, no matter how
                      short, must be recorded




                1/25/2009       National Park Service Injury and Illness   56
                                     Recordkeeping Requirements
Determining
Recordability    General Recording Criteria
                 Significant Injury/Illness (1904.7)
                     Significant Injuries or Illnesses are
                      always recordable
                     OSHA’s definition of Significant
                      Injury/illness is limited to the
                      following work-related conditions:
                           Fractured or cracked bones (including
                            teeth)
                           Punctured ear drum
                           Chronic irreversible disease
                           Occupational cancer
                1/25/2009            National Park Service Injury and Illness   57
                                          Recordkeeping Requirements
            Determination of
             Recordability

            Specific Recording
                 Criteria
              (1904.8 – 1904.11)


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                    Recordkeeping Requirements
Determining
Recordability    Specific Recording Criteria

                     The following sections deal with
                      these special circumstances:
                         Needlestick and sharps injuries
                          (1904.8)
                         Medical Removal (1904.9)

                         Hearing Loss (1904.10)

                         Tuberculosis (1904.11)




                1/25/2009         National Park Service Injury and Illness   59
                                       Recordkeeping Requirements
Determining
Recordability    Specific Recording Criteria
                 Needlesticks & Sharps (1904.8)
                     Work-related needlesticks and cuts
                      from sharp objects that are
                      contaminated with blood or potentially
                      infectious material are recordable as an
                      injury
                     If the employee is later diagnosed with
                      a bloodborne disease, the system must
                      be updated to reflect the new outcome
                      and changed to an illness

                1/25/2009         National Park Service Injury and Illness   60
                                       Recordkeeping Requirements
Determining
Recordability    Specific Recording Criteria
                 Needlesticks & Sharps (cont.)
                     Blood splashes are not recordable
                      unless they meet the general
                      recording criteria:
                           Days Away, Restriction/Transfer,
                            Medical treatment beyond first aid, or
                           Diagnosis of a bloodborne disease
                     If diagnostic tests reveal that the
                      employee contracted a bloodborne
                      disease, then the case would be
                      recordable as an illness

                1/25/2009             National Park Service Injury and Illness   61
                                           Recordkeeping Requirements
Determining
Recordability    Specific Recording Criteria
                 Medical Removal (1904.9)
                     If an employee is medically removed
                      under the medical surveillance
                      requirements of a specific OSHA
                      standard, you must record the case
                     If the case involves voluntary
                      medical removal before the criteria
                      are met, you do not need to record
                      the case


                1/25/2009       National Park Service Injury and Illness   62
                                     Recordkeeping Requirements
Determining
Recordability    Specific Recording Criteria
                 Hearing Loss (1904.10)
                     Is the hearing loss work-related?
                     Has the employee suffered a Standard
                      Threshold Shift (an average 10dB loss
                      relative to the most current baseline at
                      2000, 3000, and 4000 Hz) in one or
                      both ears corrected for aging?
                     Is the employee’s overall hearing level
                      at 25dB or more from audiometric
                      zero?
                     If yes to all above - RECORD
                1/25/2009        National Park Service Injury and Illness   63
                                      Recordkeeping Requirements
Determining
Recordability    Specific Recording Criteria
                 Tuberculosis (1904.11)

                     If the employee has been
                      occupationally exposed to
                      anyone with a known case of
                      active TB, and the employee
                      subsequently develops a TB
                      infection (positive skin test or
                      diagnosis) record the case.

                1/25/2009       National Park Service Injury and Illness   64
                                     Recordkeeping Requirements
        Privacy Concern Cases


             29 CFR 1904.29




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                   Recordkeeping Requirements
 Privacy Concern Cases
           For the following six types of
            cases, privacy of the injured/ill
            employee must be maintained
            when recording the incident:
               Intimate body part or reproductive
                system
               Sexual assault
               Mental illness
               HIV infection, hepatitis or tuberculosis
               Needlestick or sharps injuries
               Other illnesses – by voluntary
                employee request
           These are the only ones
            considered to be privacy cases
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                             Recordkeeping Requirements
 Privacy Concern Cases (cont.)

     In order to maintain the injured/ill
      employee’s privacy :
           The employee’s name must be omitted
            from the Log – instead “Privacy Case” is
            entered
           Other identifying information should also
            be left off the log
           A separate confidential list of case
            numbers and employee names must be
            maintained for OSHA compliance

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                           Recordkeeping Requirements
            OSHA Recordkeeping
                  Forms

                29 CFR 1904.29




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                     Recordkeeping Requirements
 Recordkeeping Forms
 Basic Information
     Use OSHA Forms
         300 Log (Excel Version)
         300A Summary (Excel Version)
     Use SMIS as the equivalent to
      OSHA Form 301 Injury/illness
      Incident Report
     Enter information within 7
      calendar days of receipt of
      information
     Update 300 Log for 5 years
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                      Recordkeeping Requirements
 Recordkeeping Forms
 Basic Information (cont.)
     You may keep the OSHA 300
      Log, and SMIS incident report
      electronically at any location as
      long as you can provide access
      to the records as required
     Ensure that privacy concern
      case information is protected in
      the electronic system
1/25/2009       National Park Service Injury and Illness   70
                     Recordkeeping Requirements
OSHA Form 300 – Log of Injuries & Illnesses
 Recordkeeping Forms
 OSHA 300 Log Completion
     The Log must be as complete and
      accurate as possible
     The completed 300 Log must be
      sent in Excel format to your Regional
      Risk Management Office by mid-
      January of the following year
     Establishment information and the
      pertinent year must be entered at the
      top of the form
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                      Recordkeeping Requirements
 Recordkeeping Forms
 OSHA 300 Log Completion (cont.)
     Column A – Case number must be
      unique. Use park acronym, calendar
      year, and sequential number ( e.g.
      YOSE-05-001)
     Column B – Employee’s name
      unless this is a privacy case
     Column C – Job title
     Column D – Date of injury/illness
     Column E – Where the event
      occurred

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                     Recordkeeping Requirements
 Recordkeeping Forms
 OSHA 300 Log Completion (cont.)
     Column F
         Description of injury or illness
         Parts of body affected

         Object/substance that directly
          injury or made the person ill




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                        Recordkeeping Requirements
 Recordkeeping Forms
 OSHA 300 Log Completion (cont.)
     Classifying the Case
         G – Death
         H – Days Away from Work

         I – Job Transfer or restriction

         J – Other recordable cases

     When using the Excel form,
      place the letter “x” in the
      appropriate column
1/25/2009          National Park Service Injury and Illness   75
                        Recordkeeping Requirements
 Recordkeeping Forms
 OSHA 300 Log Completion (cont.)
     Number of days the injured or ill
      worker was:
         K – Away from Work
         L – On job transfer or restriction




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                        Recordkeeping Requirements
 Recordkeeping Forms
 OSHA 300 Log Completion (cont.)
           Column M – check the “injury”
            column or choose one type of
            illness:
             1.   Injury
             2.   Skin disorder
             3.   Respiratory Condition
             4.   Poisoning
             5.   Hearing Loss
             6.   All Other Illnesses
1/25/2009             National Park Service Injury and Illness   77
                           Recordkeeping Requirements
OSHA Form 301 & SMIS Incident Report
 Recordkeeping Forms
 Form 301/SMIS Report Completion

     The NPS will continue to use the DOI
      Safety Management Information
      System (SMIS) as the official
      equivalent to the OSHA Form 301
      Incident Report
     Ensure the safety incident report
      narrative block and codes (a.k.a.
      “Supplemental Information” in SMIS)
      are detailed enough to answer
      questions 10-18 on the OSHA 301
      form
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                     Recordkeeping Requirements
 Recordkeeping Forms
 Form 301/SMIS Report Completion
  All NPS employee injuries/illnesses
   are to be reported in SMIS – even
   those with no claim for compensation
   (CA-1, CA-2)
  Relying only on CA-1/CA-2 data in
   SMIS for OSHA recordkeeping is not
   acceptable as compensation claim
   forms do not meet all the OSHA
   requirements for this purpose
  Ensure to protect privacy case
   information when providing access to
   reports
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                  Recordkeeping Requirements
OSHA Form 300A – Annual Summary
 Recordkeeping Forms
 Annual Summary – Completion
 (1904.32)
     Review OSHA 300 for completeness
      and accuracy
     Fill in establishment information on
      the 300A form:
           Year
           Agency Name
           Annual Average Number of Employees
           Total hours worked (include all covered
            employees)
     Fill in the totals from the 300 log
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                          Recordkeeping Requirements
 Recordkeeping Forms
 Annual Summary – Certification
     The annual summary must be
      certified (1960.67)
     The person performing the
      certification shall be the highest
      ranking manager of the
      establishment. This means the:
           Superintendent / Site Manager
           Center Director
           Director / Regional Director
           Other highest ranking manager at the
            individual establishment
1/25/2009            National Park Service Injury and Illness   83
                          Recordkeeping Requirements
 Recordkeeping Forms
 Annual Summary – Posting
     Post in a conspicuous place
      (typically where notices to
      employees are customarily posted)
     Once posted, the summary may not
      be altered, defaced, or covered by
      other material.
     Post from February 1st through April
      30th of the following year covered by
      the records
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                      Recordkeeping Requirements
 Recordkeeping Forms
 Retention & Updating (1904.33 &
 1960.69)

     Retain all forms for 5 years following
      the year that they cover
     Update the OSHA Form 300 during
      that period
     Do not update old forms (prior to
      2005)
     Don’t need to update the annual
      summary (300A form)
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                      Recordkeeping Requirements
 Recordkeeping Forms
 Providing Records to Government
 Representatives (1904.40)
     Within 4 hours of request,
      agencies must provide copies of
      records kept under 1904 to
      government representatives
         OSHA
         Health & Human Services (HHS)
         Nat’l Institute of Occupational
          Safety & Health (NIOSH)
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                      Recordkeeping Requirements
        Other Injury and Illness
           Recordkeeping
            Requirements
            29 CFR 1904 Subpart D
              (1904.30 – 1904.38)
                       &
                   1960.2(h)


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                     Recordkeeping Requirements
 Other Requirements
 Multiple Business Establishments
 Definition
 A location where independently
 managed NPS activities are performed
 at a single physical location
 Examples include:
           Grand Canyon NP & Albright Training
            Center
           Harpers Ferry NHP & Harpers Ferry
            Design Center
           Denver Service Center & Intermountain
            Regional Office

1/25/2009            National Park Service Injury and Illness   88
                          Recordkeeping Requirements
 Other Requirements
 Multiple Business Establishments
 Recordkeeping Requirements:
  Separate 300 log for each
   establishment
  Centralized recordkeeping
   allowed if 300 logs are accessible
   for each within 4 hours
  Link employees to a specific
   establishment
1/25/2009   National Park Service Injury and Illness   89
                 Recordkeeping Requirements
 Other Requirements
 Covered Employees (1904.31)
     Recordable injuries and illnesses
      experienced by all employees on the
      payroll and any “day-to-day”
      supervised employees must be
      included on the OSHA 300 log
     Recordable injuries and illnesses to
      volunteers who receive any kind of
      compensation (e.g. stipend, housing,
      mileage, food, etc.) from the NPS
      must be included on the log
1/25/2009       National Park Service Injury and Illness   90
                     Recordkeeping Requirements
 Other Requirements
 Employee Involvement (1904.35)
  You must inform each employee
   how to report an injury or illness
         You must set up a way for
          employees to report work-related
          injuries and illnesses promptly;
          and
         You must tell each employee how
          to report work-related injuries and
          illnesses to you

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                       Recordkeeping Requirements
 Other Requirements
 Access to Records (1904.35)
     You must provide limited access
      to injury and illness records for
      employees, former employees
      and their personal and
      authorized representatives
         Personal representative is lawyer
         Authorized representatives are
          collective bargaining units (unions)

1/25/2009         National Park Service Injury and Illness   92
                       Recordkeeping Requirements
 Other Requirements
 Access to Records (cont.)
     Upon request, a copy of the 300 Log must
      be provided by the next business day to
      employees
     Upon request, a copy of the employee’s
      own form 301 injury and illness incident
      record must be provided by the next
      business day
     The union has access to the form 301
      within 7 days (questions 10-18 only)
     BE SURE TO PROTECT PRIVACY
      CASES

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                       Recordkeeping Requirements
 Other Requirements
 Discrimination (1904.36 & 1960.68)
     1960.68 Prohibition against
      discrimination
           Agencies shall “…assure that no
            employee is subject to restraint,
            interference, coercion, discrimination or
            reprisal for filing a report of an unsafe or
            unhealthy working condition, or other
            participation in agency occupational
            safety and health program activities”
     Filing an incident report and entering
      a case on the log is a protected
      activity

1/25/2009             National Park Service Injury and Illness   94
                           Recordkeeping Requirements
       Fatality & Multiple
     Hospitalization Incidents


            29 CFR 1904 Subpart E

              1904.39 – 1904.42
              1960.29 & 1960.70


1/25/2009       National Park Service Injury and Illness   95
                     Recordkeeping Requirements
 Fatality & Multiple
 Hospitalization Incidents
 Incident Investigation (1960.29)
     Each work-related incident which
      results in a fatality or the
      hospitalization of three or more
      employees shall be investigated to
      determine the causal factors involved
     Except to the extent necessary to
      protect employees and the public,
      evidence at the scene of an accident
      shall be left untouched until inspectors
      have an opportunity to examine it

1/25/2009        National Park Service Injury and Illness   96
                      Recordkeeping Requirements
 Fatality & Multiple
 Hospitalization Incidents
 Incident Notification (1904.39 & 1960.70)
     Superintendent must provide an oral
      report to OSHA within 8 hours about
      any work-related fatality or incident
      involving 3 or more in-patient
      hospitalizations
     OSHA 1-800-321-0SHA (6742)
     Report to Department and Agency
      as required by policy
     Must report all employee fatal heart
      attacks to OSHA

1/25/2009        National Park Service Injury and Illness   97
                      Recordkeeping Requirements
 Fatality & Multiple
 Hospitalization Incidents
 Incident Summaries (1960.70)
     Follow NPS serious incident
      investigation reporting procedures
     A summary report of each fatal and
      catastrophic incident investigation
      must be provided by the WASO Risk
      Management Office to the OSHA
      Office of Federal Agency Programs


1/25/2009       National Park Service Injury and Illness   98
                     Recordkeeping Requirements
      Annual OSHA Injury and
          Illness Survey


            29 CFR 1904.41




1/25/2009   National Park Service Injury and Illness   99
                 Recordkeeping Requirements
 Annual Survey (1904.41)

     Survey for OSHA
           If you have been selected to
            participate in the OSHA injury and
            illness survey, you must respond
            within 30 days or you may be
            subject to inspection and citation




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                         Recordkeeping Requirements
      Resources and Tips for
      Effective Recordkeeping




1/25/2009   National Park Service Injury and Illness   101
                 Recordkeeping Requirements
 Resources
           Start with the OSHA Forms Package
           OSHA Recordkeeping Web Site
           OSHA Recordkeeping Handbook and on-
            line FAQ which include in depth
            information for each section of the 1904
            standard:
             The Regulatory Text
             Preamble Discussion
             Frequenly Asked Questions
             Letters of Interpretation
           WASO Risk Management Office and web
            site
           Regional Risk Management Offices

1/25/2009             National Park Service Injury and Illness   102
                           Recordkeeping Requirements
 Traits of a Good Recordkeeper

     The key to accurate, helpful, and
      compliant records is a good
      recordkeeper. That’s someone who:
           Is proactive
           Consults all sources of information
                Incident reports
                Workers’ compensation data
           Performs continual information review
           Maintains complete documentation


1/25/2009               National Park Service Injury and Illness   103
                             Recordkeeping Requirements
        Thank You
   For Participating in the
     NPS Injury/Illness
  Recordkeeping Training!



1/25/2009   National Park Service Injury and Illness   104
                 Recordkeeping Requirements

								
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