Osha and Training Records and Maintenance

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					OSHA Recordkeeping Training –
      New Regulation
             Course Outline
1.0   Overview
2.0   Recording Injuries & Illnesses
3.0   Maintenance & Retention of Records
4.0   Posting Requirements
             1.0 Overview
 Federal OSHA, under Clinton
  Administration, made changes to the
  requirements for recording work related
  injuries and illnesses.
 California must adopt a regulation as
  effective by the end of December.
    “Records” Consist of Three
 OSHA 300: Log of Occupational Injuries
  and Illnesses
 OSHA 300A : Annual Summary of
  Occupational Injuries and Illnesses
 OSHA 301: The Supplementary Record of
  Occupational Injury and Illnesses.
  Equivalent to Form 5020, Employer’s
  Report of Occupational Injury or Illness
      2.0 Recording Injuries &
 “Recordable” Cases only
 Recording an injury or illness under the
  OSHA System does not imply that an
  employer was at fault, that the worker was
  at fault, that a violation of an OSHA
  standard has occurred. Or that the injury or
  illness will be compensable under Workers’
  Compensation. It is not an admission of
                     Key Terms
    Recordable: Any work-related injury or illness
     in the work environment that is a new case and
     results in:
    1.   Loss of consciousness
    2.   Restricted work activity or job transfer
    3.   Days away from work not counting the day of injury
    4.   Medical treatment beyond first aid
    5.   Fatality
    6.   Diagnosed occupational illness
   Work Environment – The establishment &
    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 an employee during the
    course of his/her work.
        Clarification – Work
        Environment is Not:
 If the employee was injured when in the
  work environment as a member of the
  general public
 The injury/illness involves signs or
  symptoms that surface at work but result
  solely from a non-work-related event that
  occurs outside the work environment
 The injury/illness results solely from
  voluntary participation in a wellness
  program or in a medical, fitness, or
  recreational activity
         Clarification – Work
         Environment is Not:
 The injury/illness is solely the result of an
  employee eating, drinking, or preparing
  food or drink for personal consumption.
 The injury/illness is solely the result of an
  employee doing personal tasks at the
  establishment outside of the employee’s
  assigned working hours.
 The injury/illness is solely the result of
  personal grooming, self-medication for a
  non-work-related condition or is
  intentionally self-inflicted.
         Clarification – Work
         Environment is Not:
 The injury/illness is caused by a motor
  vehicle accident & occurs on a company
  parking lot or company access road while
  the employee is commuting to/from work.
 The illness is the common cold or flu.
 The illness is a mental illness unless a
  psychiatrist or psychologist has stated that
  the employee has a mental illness that is
   New Case:
    – The employee has not previously experienced a
      recorded injury/illness of the same type that affects the
      same body part, or
    – The employee previously experienced a recorded
      injury/illness of the same type that affected the same
      part of the body but had recovered completely from the
      previous injury/illness and an event or exposure in the
      work environment caused the signs or symptoms to
       New Case Clarification
 For occupational illnesses where the signs
  or symptoms may recur or continue in the
  absence of an exposure, the case must only
  be recorded once.
 The episode is a new case if the symptoms
  (e.g., occupational asthma) are the result of
  an event or exposure
   Medical Treatment: The management & care of
    a patient to combat disease or disorder.
   Does not include:
    – Visits to a physician solely for observation or
    – Diagnostic procedures such as x-rays or blood tests,
      including the administration of prescription medications
      used solely for diagnostic purposes (e.g., eye drops to
      dilate pupils).
    – First Aid Treatment
   First Aid:
    – Using a nonprescription medication at nonprescription
    – Administering tetanus immunizations (other
      immunizations such as Hepatitis B 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, butterfly bandages, or Steri Strips (sutures,
      staples, etc are considered medical treatment)
          Definition Continued:
   Using hot or cold therapy
   Using any non-rigid means of support, such as
    elastic bandages, wraps, non-rigid back belts
    (devices with rigid stays are considered medical
   Using temporary immobilization devices while
    transporting an accident victim
   Drilling of a fingernail or toenail to relieve
    pressure, or draining fluid from a blister
   Using eye patches
          Definition Continued:
   Removing foreign bodies from the eye using only
    irrigation or a cotton swab
   Removing splinters or foreign material from areas
    other than the eye by irrigation, tweezers, cotton
    swabs, etc.
   Using finger guards
   Using massages (physical therapy or chiropractic
    treatment are considered medical treatment)
   Drinking fluids for relief of heat stress
   Pre-existing Conditions: An injury/illness
    is a pre-existing condition if it resulted
    solely from a non-work-related event or
    exposure that occurred outside the work
              More Recordables
   A pre-existing injury/illness should be recorded if
    it is significantly aggravated when an
    event/exposure in the work environment results in
    any of the following:
    – Death, provided that the pre-existing injury/illness
      would likely not have resulted in death but for the
      occupational event or exposure
    – Loss of consciousness
    – One or more days away from work, or days of restricted
      work, or days of job transfer
    – Medical Treatment if not needed before the workplace
      event or exposure
   Injuries or Illnesses that occur while an
    employee is on travel status are work-
    related if, at the time of the injury/illness,
    the employee was engaged in work
    activities “in the interest of the employer.”
    – Examples include: travel to/from customer
      contacts, entertaining or being entertained to
      transact, discuss, or promote business, seminars
      or conferences
            Travel Clarification
   Not work related when:
    – Employee is checking into a hotel, motel, or
      other temporary residence
    – Employee is on a personal detour from a
      reasonably direct route of travel (e.g., has taken
      a side trip for personal reasons)
             Working at Home
   Injuries/Illnesses that occur while an
    employee is working at home will be
    considered work-related if the injury/illness
    occurs while the employee is performing
    work for pay or compensation in the home,
    and the injury/illness is directly related to
    the performance of work rather than to the
    general home environment or setting.
              New Recordables
   Tuberculosis if evidenced by a positive skin test or
    diagnosed by a physician
   Medical Removal – Employee is removed from a
    their position under a medical removal provision
    in Title 8 regardless of the presence of diagnosis
    of an injury/illness. Must be recorded as days
    away from work or restricted work activity. Use
    column “poisoning” (e.g., benzene, cadmium,
    methylene chloride, lead, formaldehyde)
     New Recordables Continued
   Needlestick and Sharps Injuries
    – All work-related needlestick injuries and cuts from
      sharp objects that are contaminated with another
      person’s blood or other potentially infectious material
      should be entered as an injury. To protect privacy,
      employee’s name may not be entered on OSHA 300 log
      instead enter “privacy case.”
    – If employee is diagnosed with an infectious bloodborne
      disease, update description and change classification
      from an injury to an illness
    – If employee is splashed with blood or OPIM, record if
      it results in a bloodborne illness
   Privacy Concern Case:
    – Injury/illness to an intimate body part or the
      reproductive system
    – Injury/illness resulting from a sexual assault
    – Mental illnesses
    – HIV Infection, hepatitis, or tuberculosis
    – Needlestick injuries and cuts from sharp objects
    – Illnesses in which an employee independently
      and voluntarily requests that his/her name not
      be entered on the log
    Rules for Counting Lost Days
 Count calendar days and cap at 180
 Do not include day of injury
 Stop counting if a physician release an
  employee to work but employee fails to
  show up
 Special circumstances –injury before
  vacation or weekend
    Rules for Counting Restricted
       Days or Transfer Days
   Record if employee is kept from performing one
    or more routine duties
   Do not have to record if restriction is only for day
    of injury
   Recommended restrictions are only recorded if
    employee is kept from performing one or more
    routine job duties
   A partial shift because of an injury is counted as a
    day of restriction
   Stop counting if employee’s job has been
    permanently modified or changed
   Count calendar days and cap at 180
3.0 Maintenance & Retention of
   Each department must maintain their own
    OSHA 300s, 300As and 301s. Records
    must be maintained centrally but must be
    made available upon request to any
    employee, former employees, authorized
    employee representative, or Cal/OSHA
               OSHA 300
 Recordable entries must be made within
  seven (7) calendar days after receiving
  information that a recordable injury/illness
  has occurred.
 Any changes to previous entries must also
  be made within seven (7) calendar days of
  dutiful knowledge of such a change.
 The log must be kept complete and updated
  to within 45-calendar days.
        OSHA 300 Continued
 All log totals must be adjusted accordingly
  to reflect any changes.
 Must be retained for 5 years and must be
  updated to include newly discovered
  recordable injuries/illnesses and any
  changes in classification of injury/illness
 Send to City Safety Office at the
  beginning of each month
              OSHA 300A
 Total columns G – M on OSHA 300 and
  transfer to 300A at the end of the calendar
 Does not have to be updated during 5 year
 Must be signed by City Safety Officer, City
  Manager, Assistant City Manager, or
  Deputy City Manager
               OSHA 301
 Departments must complete and file this
  form within seven (7) calendar days of
  receipt of information on a recordable injury
  or illness
 May use 5020 in lieu of 301
 Must be retained for five (5) years
    4.0 Posting Requirements
Only Form 300A is posted
WHY: Employee right to information

WHERE: Conspicuous place or places where
 employee notices are customarily posted

WHEN: From February 1 to April 30
              Target Dates
 Begin logging injuries/illnesses on 300 Log
  starting January 1
 Use OSHA 200 Log for calendar year 2001
The End
       Questions
       Exercise
       Thank you for

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