Development, Validation, Implementation and Enhancement of a Voluntary Protection Programs Center of

1
Development, Validation, Implementation and
Enhancement of a Voluntary Protection Programs
Center of Excellence (VPP CX) Capability for
Department of Defense (DoD)

• Recordkeeping Decision Making Process

Department of Defense Voluntary Protection
Programs Center of Excellence Operated by
DoD Lead AgentOffice of the Assistant
Secretary of the Army (Installations and
Environment)
2
Objectives

• After this training you will be able to
• Maintain accurate injury and illness records
• Complete the e-VPP Action Plan Hazard Analysis
  element Occupational Health Care Program
  Recordkeeping
• Conduct more comprehensive incident
  investigations
• Identify recordable mishap trends.

3
OSHA Injury and Illness Recordkeeping

• There is a 5 step process to OSHA Injury and
  Illness Recordkeeping

4
Step 1 Scenarios

• Scenario A
• After working seven hours entering computer data
  a worker reports a complaint of painful wrists.
  The employee is given 2 Excedrin at the base
  clinic and returns to the job.

• Scenario B
• There is a chlorine gas leak at the base swimming
  pool and 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?
5
Step 1 Scenarios

• Scenario A
• After working seven hours entering computer data
  a worker reports a complaint of painful wrists.
  The employee is given 2 Excedrin at the base
  clinic and returns to the job.

• Scenario B
• There is a chlorine gas leak at the base swimming
  pool and two (2) employees in the area are rushed
  to the hospital. They are told to stay home the
  next day as a precautionary measure.

It Depends!
Stop Here OR Go On To The Next Step?
Return to Step 1 Scenarios
6
Step 2
YES!
Return to Step 1 Scenarios
7
Determination of Work-Relatedness

• An injury or illness must be considered
  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.

8
Non-Work Related Situations

• If there is no discernable cause the
  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.

9
Non-Work Related Situations

• 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), i.e. the
  employee is injured by cutting his sandwich while
  eating lunch in the employers establishment.

10
Non-Work Related Situations

• 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.

11
Non-Work Related Situations

• 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 (psychiatrist,
  psychologist, psychiatric nurse practitioner,
  etc.) stating that the employee has a mental
  illness that is work-related.

12
Step 2 Scenarios

• Scenario A
• Employee sprains ankle in company parking lot on
  their way in to work.

• Scenario B
• Employee slips and falls in hallway, breaking an
  arm while working on sons science project on the
  employees day off.

Stop Here OR Go On To The Next Step?
13
Step 2 Scenarios

• Scenario A
• Employee sprains ankle in company parking lot on
  their way in to work.

• Scenario B
• Employee slips and falls in hallway, breaking an
  arm while working on sons science project on the
  employees day off.

It Depends!
Stop Here OR Go On To The Next Step?
Return to Step 2 Scenarios
14
OSHA 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

15
Step 3
YES!
YES!
Return to Step 2 Scenarios
16
Determination of 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.
• 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) and an
  event or exposure in the work environment caused
  the signs or symptoms to reappear.

17
Step 3 Scenario

• 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.

• 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 for pain
  throughout this period of time.

Scenario C Employee fractures foot at work.
Every six months or so it bothers him and he is
placed on light duty for a day or two.
Stop Here OR Go On To The Next Step?
18
Step 3 Scenario

• 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.

• 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 for pain
  throughout this period of time.

Scenario C Employee fractures foot at work.
Every six months or so it bothers him and he is
placed on light duty for a day or two.
STOP!
Stop Here OR Go On To The Next Step?
Return to Step 3 Scenarios
19
Step 3 Scenario

• 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.

• 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 for pain
  throughout this period of time.

Scenario C Employee fractures foot at work.
Every six months or so it bothers him and he is
placed on light duty for a day or two.
It Depends!
Stop Here OR Go On To The Next Step?
Return to Step 3 Scenarios
20
Step 4
YES!
YES!
YES!
Return to Step 3 Scenarios
21
General Recording Criteria

• An injury or illness meets general recording
  criteria and is recordable if it results in
• Death
• Days away from work, restricted work or transfer
  to another job
• Medical treatment beyond first aid or
• Loss of consciousness
• Injury and illness cases diagnosed by a physician
  or other licensed health care professional are
  still recordable, even if they do not meet the
  above results

22
Step 5
23
Day Counts

• Count the number of calendar days the employee
  was away from work or restricted/transferred
  (include weekend days, holidays, vacation days,
  etc.)
• Cap the day count at 180 days away and/or days
  restricted.
• Stop the 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.

24
Medical Treatment vs First Aid

• Medical treatment DOES NOT include
• Visits to a physician or other licensed health
  care professional solely for observation or
  counseling only
• 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)
• First Aid

25
Medical Treatment vs First Aid

• 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.
• Any number of hot-cold treatments is First Aid.
• Administering tetanus immunizations is First Aid.
• Cleaning, flushing or soaking wounds on the
  surface of the skin is First Aid.

26
Medical Treatment vs 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.
• Using any non-rigid means of support, as elastic
  bandages, wraps, back belts, etc. is First Aid.
• Using wound coverings such as
  Band-Aids Butterfly bandage/
  Steri-Strip (the
  only kind of wound closures) are
  First Aid.

27
Medical Treatment vs First Aid

• Even 1 dose of prescription meds is considered
  Medical Treatment
• Over the Counter meds 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
• Over the counter non-prescription
• med at non-prescription strength is
• First Aid

28
Significant Diagnosed Injury or Illness

• An injury or illness that is automatically
  recordable if work related
• Fracture of bones or teeth
• Punctured ear drum
• Cancer
• Chronic irreversible disease
• (e.g., silicosis).

29
Determining Case Severity

• Employee has a work-related injury or illness,
  sees doctor, told she can only work on light duty
  for the next two weeks. Normally scheduled for
  five day workweeks. How many days of restricted
  work activity should be entered on the OSHA Log?

30
Hearing Loss Recordability

• 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

31
Bloodborne Pathogen Recordability

• 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.

32
OSHA Forms

• 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.

33
OSHA 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.

34
Covered Employees

• Employees on payroll
• Employees not on payroll who are supervised on a
  day-to-day basis
• Temporary help agencies should not record the
  cases experienced by temp workers who are
  supervised by installation personnel

35
Annual Summary OSHA 300A

• Federal establishments certification
• The senior establishment management official
• The head of the Agency for which the senior
  establishment management official works, or
• Any management official who is in the direct
  chain of command between the senior establishment
  management official and the head of the agency
  head
• Must post for 3-month period from February 1 to
  April 30 of the year following the year covered
  by the summary

36
Reporting Information to the Government

• Fatality and catastrophe reporting
• Access for Government representatives

37
e-VPP Tool Mapping

• This training can be used as part of your sites
  documentation of action taken to address the
  following VPP actions
• e-VPP Action Plan Hazard Analysis element
  Occupational Health Care Program Recordkeeping
  Safety and Health Training
• SH Training for Staff and Others with
  Assigned SH Responsibilities
• A1. A5.  Conducting an Assessment of Workplace
  SH Practices
• A1. Trend Analysis
• A1. A5. A6 .A7  Hazard Elimination and Control
  Methods
• Records of training attendance and verification
  of 80 comprehension are indicators of World
  Class performance

38
For More Help

• OSHAs Recordkeeping Page-
• http//www.osha.gov/recordkeeping/index.html
• OSHA Regional Recordkeeping Coordinators

39
Summary

• In this session you learned about
• Accurate injury and illness records
• Requirements for reporting and retaining injury
  and illness records
• Comprehensive incident investigations
• Trending recordable mishaps

40
Questions?