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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 wor
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1. 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
2. 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
3. Recordkeeping Goals Improve Data
Simplify forms and requirements
Maximize use of computers
Improve employee involvement
Protect privacy
4. 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**
5. 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.
6. 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
7. Recording Criteria Eliminates different criteria for recording work-related injuries and illnesses
Former rule required employers to record all illnesses, regardless of severity
8. 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
9. 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.
10. 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
11. 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
12. 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
13. 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
14. Recording Criteria Decision Tree
15. 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
16. 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
17. 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
18. 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.
19. 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
20. 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
21. 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
22. 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
23. 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
