OSHA LOG Recordkeeping

1. OSHA LOGRecordkeeping Brian Zaidman Senior Research Analyst Minnesota Dept. of Labor and Industry MN Dept of Labor & Industry

2. Goals of Presentation • General recordkeeping review • Recording needlesticks, exposures and infections • Special recordkeeping topics MN Dept of Labor & Industry

3. MN Dept of Labor & Industry

4. The not so Secret Key to recordkeeping success • Read the instructions that come in the log packet • Read the log before you begin filling it out • If you don’t understand something, ask someone • If you need training, get training • If someone asks you for recordkeeping training, approve it immediately MN Dept of Labor & Industry

5. Is an injury or illness recordable? • “recordable” means countable as an injury or illness case of sufficient severity to merit inclusion in the log • Completely separate from workers’ compensation • Even if your workers’ comp insurer denies a claim, it still might be a recordable case MN Dept of Labor & Industry

6. Recordable if: • Work-related injury or illness • Time away from work, job restriction or transfer, or medical treatment beyond first aid • Loss of consciousness • Not a recurrence of an ongoing chronic condition MN Dept of Labor & Industry

7. Recordkeeping: Worker and injury/illness description • Name • Occupation • Date of event • Location of event • Event and injury description • Can use multiple lines in form MN Dept of Labor & Industry

8. Describing injury and illness cases • Activity worker engage in • Nature of injury (what) • Part of body injured (where) • Source(s) of injury (object or substance) • Event or exposure (how) MN Dept of Labor & Industry

9. Case classification • Fatality • Day away from work • Job transfer or restriction • Other recordable • Not recordable MN Dept of Labor & Industry

10. Needlesticks and Sharps injuries • Must be a contaminated object • Blood or potentially infectious material • Record as an injury (column M) • Do not enter worker’s name • Use “Privacy concern case” • If no time away from work or restrictions, then this is an “other recordable” case MN Dept of Labor & Industry

11. Needlesticks and Sharps injuries (cont.) • If the worker later is diagnosed with an infectious bloodborne disease • Update log to indicate illness • Change description to include type of illness • Change case classification, if needed MN Dept of Labor & Industry

12. Immunizations and Inoculations • Not recordable unless a work-related injury or illness has occurred • If in response to a needlestick or exposure to bloodborne pathogen, then case is already recordable • Worker must first test positive for exposure or infection for a non-needlestick/sharps incident to be recordable MN Dept of Labor & Industry

13. Tuberculosis cases • Must record where • Worker has been exposed in the workplace to anyone with an active TB case • Worker subsequently develops a TB infection • Classified as a respiratory infection • Date of illness is the date of diagnosis MN Dept of Labor & Industry

14. Privacy concern cases • ONLY use “Privacy concern case” for • Injuries to intimate body parts or reproductive systems • Injury or illness resulting from sexual assault • Mental illness MN Dept of Labor & Industry

15. Privacy concern cases (cont.) • ONLY use “Privacy concern case” for • HIV infection, hepatitis or TB • Contaminated needlesticks and cuts from sharp objects • Other illnesses, if worker independently and voluntarily asks • These are the ONLY allowable uses MN Dept of Labor & Industry

16. Privacy concern cases (cont.) • Can also be vague about description to help protect worker’s identify • Gender and job title • Keep a separate list that matches name to each case • Used for updating information • May be needed by OSHA MN Dept of Labor & Industry

17. OSHA log example • Review cases entered on handout MN Dept of Labor & Industry

18. OSHA log maintenance • Maintain log for 5 years following end of calendar year • Update information if cases change • Do not need to update summary MN Dept of Labor & Industry

19. Re-injury and recurring cases • A chronic illness case is only recorded once if workplace exposure is not needed for signs or symptoms to recur • To be a new case, worker needs to have completely recovered from the previous illness • If symptoms triggered by workplace exposure, must record as a new case MN Dept of Labor & Industry

20. Relation to workers’ compensation • OSHA recordkeeping requirements are different from WC laws • An injury may be counted in one system and not in the other • Each system has its own system for determining work-relatedness • Some workers not covered by WC are considered employees for OSHA MN Dept of Labor & Industry

21. Recordkeeping: Final thoughts • Recordkeeping can be complicated • Needs to be consistent, comparable and correct to be useful • Review your site’s log information regularly, keep it accurate • Use available resources to maintain record quality MN Dept of Labor & Industry

22. Contact Brian by: • E-mail: brian.zaidman@state.mn.us • Phone: 651-284-5568 • DLI Research and Statistics Web site: http://www.dli.mn.gov/Research.asp • Or show up in person MN Dept of Labor & Industry