OSHA INJURY AND ILLNESS RECORDKEEPING

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OSHA INJURY AND ILLNESS RECORDKEEPING Part 1904
Basics for Federal Agencies Bob Whitmore
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OSHA INJURY AND ILLNESS RECORDKEEPING
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1904 for Federal Agencies took effect 1/1/2005

• 2005 is a transition yearOSHA wont enforce
  regulation.
• 1/1/2006 OSHA can begin enforcement we
  obviously will be looking at 2005 Logs etc.
  SOuse this year to produce accurate, complete
  2005 records !!

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POP QUIZTrue or False

• All Workers Comp cases are OSHA Recordable ?

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ANSWER

• I have NO Clue !!!
• Cases are OSHA recordable Only IF they meet the
  OSHA requirements.

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WARNING !!!

• IF YOU ARE HERE TO LEARN OR DISCUSS Workers Comp.
  You are in the Wrong Room !!!!
• OSHA Recordkeeping and Workers Comp. are totally
  Unrelated Systems !!

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2nd WARNING DO NOT MIXOSHA RECORDABILITY AND
WORKERS COMPENSATION

• Workers Compensation determinations do NOT
  impact OSHA recordability.
• Some cases may be OSHA recordable and
  compensable.
• Some cases may be compensable, but not OSHA
  recordable.
• Some cases may be OSHA recordable, but not
  compensable.

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OSHA INJURY AND ILLNESS RECORDKEEPING 5
STEP PROCESS
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Did the employee experience an injury or illness?
YES
YES
YES
Does the injury or illness meet the general
criteria or the application to specific cases?
YES
Record the Injury or illness.
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1904.46 Did the employee experience an
injury or illness? STEP 1
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Step 1 Did the employee experience an injury or
illness?
Injury or illness. An injury or illness is an
abnormal condition or disorder. Injuries include
cases such as, but not limited to, a cut,
fracture, sprain, or amputation. Illnesses
include both acute and chronic illnesses, such
as, but not limited to, a skin disease,
respiratory disorder, or poisoning. (Note
Injuries and illnesses are recordable only if
they are new, work-related cases that meet one or
more of the Part 1904 recording criteria.)
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Step 1 Did the employee experience an injury or
illness?
Scenario A A worker reports to nurses station
with complaint of painful wrists. Employee given
2 Advil and returned to job.
Stop Here OR Go On To The Next Step?
Answer Go on to the next step.
Why Painful wrists was the injury experienced.
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Step 1 Did the employee experience an injury or
illness?
Scenario B There is a chlorine gas leak at XYZ
establishment and the two (2) employees in the
area are rushed to the hospital. They are told
to stay home the next day as a precautionary
measure.
Stop Here OR Go On To The Next Step?
Answer It depends ! ! We need more information.
Why We need to know if either employee
exhibited signs or symptoms of an
injury/illness. If yes, then go to the next
step. If no, STOP. We have an event or exposure
only.
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Did the employee experience an injury or illness?
YES
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Step 2 Is the injury or illness work-related?
Determination of work-relatedness You must
consider an injury or illness to be work-related
if an event or exposure in the work environment
either caused or contributed to the resulting
condition or significantly aggravated a
pre-existing injury or illness.
Work-relatedness is presumed for injuries and
illnesses resulting from events or exposures
in the work environment unless an exception
specifically applies.
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The following situations are not work-related
1. There is no discernable cause.
Injury/illness did not result from event/exposure
at work.

• At the time of the injury or illness, the
  employee was present in the work environment as a
• member of the general public rather than as an
  employee.

• The injury or illness involves signs or symptoms
  that surface at work but result solely from a
  non-work related event or exposure that occurs
  outside the work environment.

• The injury or illness results solely from
  voluntary participation in a wellness program or
  in a
• medical, fitness, or recreational activity such
  as blood donation, physical examination, flu
  shot, exercise class, racquetball, or baseball.

• The injury or illness is solely the result of an
  employee eating, drinking, or preparing food or
• drink for personal consumption (whether bought
  on the employers premises or brought in).
• For example, if the employee is injured by
  choking on a sandwich while in the employers
• establishment, the case would not be considered
  work-related.

Note If the employee is made ill by ingesting
food contaminated by workplace
contaminants (such as lead), or gets food
poisoning from food supplied by the
employer, the case would be
considered work-related.
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The following situations also are not
work-related

• The injury or illness is solely the result of an
  employee doing personal tasks (unrelated to
• their employment) at the establishment outside
  of the employees assigned working hours.

• The injury or illness is solely the result of
  personal grooming, self medication for a
• non-work-related condition, or is intentionally
  self-inflicted.

• The injury or illness is caused by a motor
  vehicle accident and occurs on a company parking
• lot or company access road while the employee is
  commuting to or from work.

• The illness is the common cold or flu (Note
  contagious diseases such as tuberculosis,
• brucellosis, hepatitis A, or plague are
  considered work-related if the employee is
  infected
• at work).

• The illness is a mental illness. Mental illness
  will not be considered work-related unless
• the employee voluntarily provides the employer
  with an opinion from a physician or other
• licensed health care professional with
  appropriate training and experience
  (psychiatrist,
• psychologist, psychiatric nurse practitioner,
  etc.) stating that the employee has a mental
• illness that is work-related.

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3rd WARNING DO NOT MIXOSHA RECORDABILITY AND
WORKERS COMPENSATION

• Workers Compensation determinations do NOT
  impact OSHA recordability.

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Step 2 Is the injury or illness work-related?
Scenario A Employee gives blood at voluntary
employer sponsored blood drive and passes out
losses consciousness.
Stop Here OR Go On To The Next Step?
Answer Stop Here
Why? Exception 4 - The injury or illness
results solely from voluntary participation in a
wellness program or in a medical, fitness, or
recreational activity such as blood donation,
physical examination, flu shot, exercise class,
racquetball, or baseball.
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Step 2 Is the injury or illness work-related?
Scenario B Employee sprains ankle in company
parking lot on way in to work.
Stop Here OR Go On To The Next Step?
Answer Go on
Why? There is no exception that applies.
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Step 2 Is the injury or illness work-related?
Scenario C Employee slips and falls in hallway
while working on daughters science project on
Saturday, employees day off.
Stop Here OR Go On To The Next Step?
Answer Stop
Why? Exception 6 - The injury or illness is
solely the result of an employee doing personal
tasks (unrelated to their employment) at the
establishment outside of the employees assigned
working hours.
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Did the employee experience an injury or illness?
YES
YES
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Step 3 Is the injury or illness a new case?
Determination of a new case Consider an
injury or illness a new case if the employee
has not previously experienced a recorded
injury or illness of the same type that affects
the same part of the body, OR the
employee previously experienced a recorded
injury or illness of the same type that
affected the same part of body but had
recovered completely (all signs and symptoms
had disappeared) from the previous injury or
illness and an event or exposure in the work
environment caused the signs or symptoms to
reappear.
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Step 3 Is the injury or illness a new case?
Scenario A Five (5) weeks ago, employee
sprained wrist at work and received support,
prescription medication, and light duty. Two
weeks ago employee was back on normal job. Today
(5 weeks after the injury) employee complains of
pain in same wrist after moving boxes.
Stop Here OR Go On to the Next Step?
Answer Go on
Why? Employee was back at normal job and no
criteria for recordability was in existence at
that time.
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Step 3 Is the injury or illness a new case?
Scenario B Five (5) weeks ago employee sprained
wrist at work and received support, prescription
medication, and light duty. Two weeks ago
employee was back on normal job. Today (5 weeks
after the injury) employee complains of pain in
same wrist after moving boxes. Employee
continues to take prescription medications
throughout this period of time.
Stop Here OR Go On to the Next Step?
Answer Stop
Why? Update the previously recorded injury or
illness entry if necessary.
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Did the employee experience an injury or illness?
YES
YES
YES
1904.7 Does the injury or illness meet the
general criteria or the
application to specific cases? STEP 4
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Step 4 Does the injury or illness meet the
general criteria or the application to specific
cases?
General Recording Criteria You must
consider an injury or illness to meet the general
recording criteria, and therefore to be
recordable, if it results in any of the
following death, days away from work, restricted
work or transfer to another job, medical
treatment beyond first aid, or loss of
consciousness. You must also consider a case to
meet the general recording criteria if it
involves a significant injury or illness
diagnosed by a physician or other licensed
health care professional, even if it does not
result in death, days away from work, restricted
work or job transfer, medical treatment beyond
first aid, or loss of consciousness.
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DAYS AWAY FROM WORK Count the
number of calendar days the employee was away
from work or restricted/transferred (include
weekend days, holidays, vacation days, etc.) May
cap day count at 180 days away and/or days
restricted May Stop day count if employee leaves
company for a reason unrelated to the injury or
illness. Must estimate day count when employee
leaves company due to reasons related to the
injury and illness
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Restricted Work Activity Fine Points

• Restriction/transfer limited to day of
  injury/illness onset not recordable-includes
  employee being sent home during shift.
• Production of fewer goods or services not
  considered RWA
• Vague restrictions from physician or LHCP (e.g.,
  light duty or take it easy for a week) are to
  be recorded as RWA if no further information is
  obtained.

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Medical Treatment VS First Aid
Medical treatment DOES NOT include
1. Visits to a physician or other licensed health
care professional solely for observation or
counseling only
2. Diagnostic procedures such as x-rays and blood
tests, including administration of prescription
medications used solely for diagnostic purposes
(e.g., eye drops to dilate pupils)
3. First Aid
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Medical Treatment VS First Aid contd.
First Aid list is comprehensive. Any other
procedure is medical treatment.

• Using temporary immobilization devices while
  transporting an accident victim is First Aid

- Drilling a nail is First Aid

• Using eye patches is First Aid

• Removing foreign bodies from the eye using only
  irrigation or a cotton swab is First Aid

• Removing splinters or foreign material from areas
  other than the eye by irrigation, tweezers,
  cotton swabs or other simple means is First Aid

• Using finger guards is First Aid

• Using massages is First Aid

- Drinking fluids for relief of heat stress is
First Aid
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Medical Treatment VS First Aid contd.

• Using any non-rigid means of support, as elastic
  bandages, wraps, back belts, etc. is First Aid

• 1 dose prescription med is Medical Treatment

• Over the Counter non-prescription med at
  non-prescription strength is First Aid
• OTC med at prescription strength is Medical
  Treatment
• Ibuprofen (such as Advil) -
  Greater than 467 mg
• Diphenhydramine (such as Benadryl)
  Greater than 50 mg
• Naproxen Sodium (such as Aleve)
  Greater than 220 mg
• Ketoprofen (such as Orudus KT)
  Greater than 25 mg

• Administering tetanus immunizations is First Aid

- Cleaning, flushing or soaking wounds on the
surface of the skin is First Aid

• Using wound coverings such as Band-Aids
  Butterfly bandage/Steri-Strip (the only kind of
  wound closures) are First Aid

• Any number of hot-cold treatments is First Aid

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Significant diagnosed Injury or Illness that is
automatically recordable if work related
1904.7(b)(7)
1. Fracture of bones or teeth
2. Punctured ear drum
3. Cancer
4. Chronic irreversible disease (e.g., silicosis)
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Did the employee experience an injury or illness?
YES
YES
YES
Does the injury or illness meet the general
criteria or the application to specific cases?
YES
Record the Injury or illness
STEP 5
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Hearing Loss Recordability 1904.10
OSHAs recordkeeping rule requires the employer
to record all work- related hearing loss cases
that meet BOTH of the following conditions on the
same audiometric test for either ear

• The employee has experienced a Standard Threshold
  Shift (STS)
• The employees total hearing level is 25 dB or
  more above
• audiometric zero (averaged at 2000, 3000, 4000
  Hz) in the
• same ear(s) as the STS.

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Use this decision tree to determine whether the
results of a audiometric exam given on or after
January 1, 2003 reveal a recordable STS.
No
Yes
No
Yes
No
Yes
Note In all cases, use the most current
baseline to determine recordability as you would
to calculate a STS under the hearing
conservation provisions of the noise standard
(1910.95). If an STS occurs in only one ear,
you may only revise the baseline audiogram for
that ear. The audiogram may be adjusted for
presbycusis (aging) as set out in 1910.95.
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Example 1 Employee A Right ear 2000
Hz 3000 Hz 4000 Hz
Current Test 10 15 15
Current Baseline 5 10 5
Threshold Shift 5 5
10   Avg. Threshold Shift (5510)/3 6.7 dB
Since the average threshold shift is less than 10
dB, this employee has not experienced a STS.
This case is not recordable, since experiencing a
STS is one of the conditions for recordability.
Threshold shifts are determined by subtracting
the current baseline from the current test.


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Example 2 Employee B Right ear
2000 Hz 3000 Hz 4000Hz
Current Test 10 20 20
Current Baseline 5 10
5
Threshold 5 10 15
Avg. Threshold Shift (51015)/3 10 dB
Since the avg. threshold shift is 10 dB, this
employee has experienced a STS. Now look at the
Total Hearing Level
Total Hearing Level
2000 Hz 3000 Hz 4000 Hz
Current Test 10 20 20
Avg. Total Hearing Level (102020)/3 16.7 dB
This case is not recordable since both conditions
for recordability were not met. Even though this
employee has experienced a STS, the avg. total
hearing level is less than 25 dB above
audiometric 0
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Example 3 Employee C Right ear
2000 Hz 3000 Hz 4000 Hz
Current Test 15 25 35
Current Baseline 5 10 5
Threshold Shift 10 15 30
Avg. Threshold Shift (101530)/ 18.3 dB
Since the avg. threshold shift is greater than 10
dB, this employee has experienced a STS. Now
look at the Total over all Hearing Level
Total Hearing Level
2000 Hz 3000 Hz 4000 Hz
Current Test 15 25 35
Avg. Total Hearing Level (152535)/3 25 dB
This case is recordable since both conditions for
recordability have been met on the same test.
This employee has experienced a STS and the avg.
total hearing level is 25 dB or more above
audiometric 0.
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Relationship to Bloodborne Pathogen Standard
Needlesticks and sharps injuries ALL
needlesticks and sharps injuries that are
contaminated with another persons blood or other
potentially infectious material are recordable.
Record splashes or other exposures to blood or
other potentially infectious material if it
results in diagnosis of a bloodborne disease or
meets the general recording criteria

• Employers may elect to use the OSHA 300 and 301
  forms to meet the sharps injury log requirements,
  provided two conditions are met
• The employer must enter the type and brand of the
  device on either the 300 or 301 form.
• The employer must maintain the records in a way
  that segregates sharps injuries from other types
  of work-related injuries and illnesses, or allows
  sharps injuries to be easily separated.

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1904.29 - Forms

• OSHA Form 300, Log of Work-Related Injuries and
  Illnesses
• OSHA Form 300A, Summary of Work-Related Injuries
  and Illnesses
• OSHA Form 301, Injury and Illness Incident Report

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1904.29 - Forms

• Employers must enter each recordable case on the
  forms within 7 calendar days of receiving
  information that a recordable case occurred
• An equivalent form has the same information, is
  as readable and understandable, and uses the same
  instructions as the OSHA form it replaces
• Forms can be kept on a computer as long as they
  can be produced when they are needed (i.e., meet
  the access provisions of 1904.35 and 1904.40)
• Certification by THE senior establishment
  management official on OSHA 300 A Summary Form

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Other Recording Issues 1904.31
Covered Employees Basic requirement. You must
record on the OSHA 300 Log the recordable
injuries and illnesses of all employees on your
payroll, whether they are labor, executive,
hourly, salary, part-time, seasonal, or migrant
workers. You also must record the recordable
injuries and illnesses that occur to employees
who are not on your payroll if you supervise
these employees on a day-to-day basis. If your
business is organized as a sole proprietorship or
partnership, the owner or partners are not
considered employees for recordkeeping purposes.
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Still Other Recording Issues

• TB Positive skin test recordable when known
  work place exposure to active TB disease. NO
  presumption of work relationship in any industry.
• MSD recordable when General Recording Criteria is
  met.

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For More Help on OSHA Recordkeeping

• OSHAs Recordkeeping Page-
• http//www.osha.gov/recordkeeping/index.html
• OSHA Regional Recordkeeping Coordinators
• For any help on Workers Comp please do not
• call OSHA Recordkeeping .

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