Recording Industry by nii43454

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									 Recordkeeping &
Reporting: How the
 Revised Standard
  Affects Industry

                   TECH 231
 From the University of Vermont Safety Library
Author - 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 work-
 related 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 work-
 related 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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