RECORDKEEPING

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					          RECORDKEEPING
                What Changed?


American Society of Safety Engineers – Piedmont Chapter

                     January 21, 2010


            Dottie Ison, Administrator, SC OSHA
 Gwen Thomas, Program Coordinator, Tech Support and Standards
           History of Recording Changes
   January 19, 2001 – Final Rule published

   January 1, 2002 – Effective date of Standard (with 2 exceptions)

   July 1, 2002 – OSHA issued final rule that revised the criteria for
    recording work-related hearing loss

   January 1, 2003 – Effective Date to begin recording work-related hearing
    loss if an employee experienced a STS

   January 1, 2004 – Employers required to begin using revised forms to
    include a column for recording hearing loss
        Recordkeeping Goals

 Improve Data
 Simplify forms and requirements

 Maximize use of computers

 Improve employee involvement

 Protect privacy
              Scope- Am I Covered?
   If not on the list of service and retail industries that are partially exempt
    which has been updated (listed in Appendix A to Subpart B)

   The new rule continues to provide a exemption for employers who had 10
    or fewer workers at all time in the previous calendar year (based on
    employees in entire company & temps you supervise on a day to day
    basis)

   SC is a state plan – all public sector employers must continue to keep
    Injury and Illness records

   Employers may be exempt from maintaining records, but they must
    continue to REPORT fatalities and multiple hospitalizations of 3 or more.
    New rule clarifies some reporting issues**
                          Forms

   The OSHA Form 300 (Log) has been simplified and smaller
   The OSHA Form 301 (Incident Report) includes more data
    about how the injury/illness occurred
   The OSHA Form 300A (Summary) provides additional data
    to make it easier to calculate incidence rates
   Maximum flexibility has been provided so employers can
    keep all information on computers, at a central location, or
    on alternative forms, as long as information is compatible
    and can be produce when needed.
               Recording Criteria

   To be recordable:
    * Must be work-related
    * Must be a new case
    * Must meet one or more of the general criteria
      in section 1904.7 – 1904.12
               Recording Criteria

   Eliminates different criteria for recording
    work-related injuries and illnesses

   Former rule required employers to record all
    illnesses, regardless of severity
               Work-Relatedness

   Cases are work-related if:
       An event or exposure in the work environment
       either caused or contributed to the resulting
       condition

       An event or exposure in the work
       environment significantly aggravated* a
       pre-existing injury or illness
           Work-Relatedness – con’t

   Work-relatedness is presumed for injuries/illness
    that occur in the work environment
   A case is presumed work-related if, and only if, an
    event or exposure in the work environment is a
    discernable cause of the injury/illness or of a
    significant aggravation to a pre-existing condition.
    The work event or exposure need only be one of the
    discernable causes, it need not be the sole or
    predominant cause.
          Work Related Exceptions

Add additional exceptions to the definition of work
 relationship to limit recording of cases involving:
 > eating, drinking or preparing food or drink
      for personal consumption
 > common colds and flu
 > voluntary participation in wellness or fitness
      programs
 > If employee is doing personal tasks at the
      establishment outside normal work hours
      Work Related Exceptions (con’t)

   If employee is in the work environment as a member of the
    general public
   Involves symptoms that surface at work but result solely
    from a non-work-related event
   Result of personal grooming, self-medication or self-
    inflicted
   Caused by a motor vehicle accident that occurs on a
    company parking lot or access road while commuting to or
    from work
   Mental illness is not considered work-related unless
    employee voluntarily provided an opinion form a
    physician or other LHCP that states it
           General Recording Criteria
   Requires records to include any work-related
    injury/illness resulting in one of the following:

    > Death
    > Days away from work;
    > Restricted work* or job transfer;
    > Medical treatment beyond first aid*;
    > Loss of consciousness;
    >Diagnosis by a physician or other licensed health care
      professional as a significant injury/illness
General Recording Criteria – con’t

   Includes a new definition of medical
    treatment and first aid* to simplify recording
    decisions

   Clarifies the recording of “light duty” or
    restricted work cases
     Recording Criteria Decision Tree
                               NO    D id th e emp lo y ee ex p erien ce an
                                                in ju r y o r illn ess?

                                                                YES


                                    NO               I s th e in ju r y o r
                                                illn ess w o r k -r elated ?

                                                                YES

                                                                                       NO        U p d ate th e p r ev io u sly
                                                       I s th e in ju r y                     r eco rd ed in ju ry o r illn ess
                                               o r illn ess a n ew case?                           en try if n ecessary .
                                                                YES



                          NO              D o es th e in ju r y o r illn ess meet
                                           th e g en er al r eco r d in g criter ia         YES
                                         o r th e ap p licatio n to sp ecific cases?




D o n o t r eco rd th e                                                                                   Reco r d th e
 in ju r y o r illn ess                                                                               in ju r y o r illn ess
         Recording Needlesticks


   New standard requires employers to record
    all needlesticks and sharps injuries
    involving contamination by another
    person’s blood or other potentially
    infectious material
                    Hearing Loss

 Must record all work-related hearing loss cases where
  > Employee has experienced a Standard Threshold Shift*
       (STS), and
  > Employees total hearing level is 25 decibels (dB) or more
       above audiometric zero (avg at 2000, 3000 and 4000
       hertz (Hz) in the same ear as the STS
____________________________________________________
*A STS is defined in 29 CFR 1910.95(g)(10)(i) as a change in
  hearing threshold, relative to the baseline audiogram, of an
  average of 10 dB or more at 2000, 3000 and 4000 Hz in 1 or
  both ears
Musculoskeletal Disorders (MSD)

   Applies the same recording criteria to MSDs
    as to all other injuries and illnesses

   Employer retains flexibility to determine
    whether an event or exposure in the work
    environment caused or contributed to the
    MSD
    Tuberculosis & Medical Removal


   Includes separate provisions describing the
    recording criteria for cases involving the work-
    related transmission of tuberculosis.

   Requires employers to record cases of medical
    removal under OSHA standards.
                    Day Counts


   Eliminates the term “lost workdays” and focuses
    on days away or days restricted or transferred

   Includes new rules for counting that rely on
    calendar days instead of workdays.

   Limit on how long required to track cases – now do
    not have to be counted beyond 180 days
             Employee Involvement

   Requires employers to establish a procedure for
    employees to report injuries/illnesses and let their
    employees know how to report
   Employers are prohibited from discriminating
    against employees who do report
   Employee representatives will now have access to
    those parts of the OSHA 301 form relevant to
    workplace safety and health
                   Employee Privacy

   Prohibits employers from entering an individual’s name
    on Form 300 for certain types of injuries/illnesses – a
    separate list of case numbers and names must be provided
    to OSHA upon request
   Provides employers the right not to describe the nature of
    sensitive injuries where the employee’s identity would be
    known
   Gives employee representatives access only to the portion
    of Form 301 which contains no personal information
   Requires employers to remove employees names before
    providing the data to persons not provided access rights
    under the rule
             Annual Summary


   Requires the annual summary to be posted for
    three months instead of one (February 1 –
    April 30)

   Requires certification of the summary by a
    company executive
              Additional Information

   Federal OSHA website www.osha.gov *
   SC OSHA website for updates
             www.llr.state.sc.us

   SC OSHA Office of Standards:
       Dainnya Busbin (busbind@llr.sc.gov)     803-896-7661
       Natikki Dawkins (dawkinsd@llr.sc.gov)   803-896-7682