OSHA's Revised Recordkeeping Rule 1

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1 Safe and Environmentally Friendly Equipment Maintenance Facilities Presented by Steve Frisch Sr. Safety Consultant J. J. Keller & Associates, Inc. Neenah WI 1 Objectives Enhance shop safety through safe work practices that minimize injuries to employees and damage to equipment. Deploy work practices that protect your employees and keep your shop under the radar screen of state and federal officials. Prepare your facility for an audit should OSHA or some other oversight group pays you a visit. 2 Training Designed to help employer: Identify problems that training will help Set goals and objectives Design learning activities/conduct training 3 OSHA's Revised Recordkeeping Rule 1

2 Training Designed to help employer: Determine training effectiveness Revise training program as needed Provide ongoing training 4 Safety Training OSHA requires a wide variety of workplace safety training: Training needs are based on company s overall hazard assessment results. Training must be effective. Training must be documented. 5 Safety Training Records Required training is generally required to be documented. Training records should always include: Description of training topic Trainee s name Instructor s name Date of training completion Outline (or curriculum) of training program 6 OSHA's Revised Recordkeeping Rule 2

3 Most Common Topics Powered Industrial Truck/Forklift Hazard Communication Emergency Action Plan (Policies Later) Injury & Illness Notification Requirements PPE 7 Most Common Topics Slip, Trip, and Fall Protection Lockout/Tag-out Fire Prevention Welding/Cutting/Brazing Machine Guarding 8 Typical Training Areas Electrical Safety Emergency Response Ergonomics Hand tools Lifting Confined Spaces First Aid/Bloodborne Pathogens 9 OSHA's Revised Recordkeeping Rule 3

4 Effective Training Training should include regulations AND company procedures More than just showing a video Standardized Adult based presentations ( professional education) = hands-on Employee contributions to content/delivery Enforced Consequences 10 Translate into Work Practices Rewards for safe work Use actual incidents for training Require refresher/medial training Be open and flexible to change 11 What does OSHA mean by recordkeeping? Simply put, it s those documents you maintain that pertain to your workplace safety and health efforts - some are MANDATORY! Mandatory examples include: Injury and illness records Written safety plans Safety training records 12 OSHA's Revised Recordkeeping Rule 4

5 Injury and Illness Records OSHA s main Recordkeeping Rule can be found in 29CFR 1904, Injury and Illness Recordkeeping Requirements. 13 Who s covered? Employers with more than ten employees. Smaller companies are exempt. Some industries such as low-hazard retail, service, finance, insurance, and real estate are also exempt. 14 Any incident involving these factors needs to be recorded: Death Days away from work Restricted work or transfer to another job Think D.A.R.T.! 15 OSHA's Revised Recordkeeping Rule 5

6 What s recordable? Injuries requiring medical care Medical removal Bloodborne pathogen exposures Tuberculosis exposures Work-related hearing loss Muskuloskeletal disorders (MSD) 16 Immediate Reporting ALL employers must to report to OSHA within eight hours any workplace incident that results in death or the hospitalization of three or more employees. poyees The OSHA hotline number is: OSHA 17 Beyond the I & I Regulation Facilitate employee involvement. Try to track all incidents, including those that don t fall into a recordable category, and also near misses. Analyze patterns. 18 OSHA's Revised Recordkeeping Rule 6

7 Written Safety Plans Also referred to as safety policies. Many are mandatory under OSHA regulations. Intended to provide employees with instruction on specific workplace safety practices. 19 Written Safety Plans Typical Topics: Emergency Action Plan Emergency First Aid/Bloodborne Pathogens Includes chemical exposure documentation Hazard dcommunication Powered Industrial Truck/Forklift Personal Protective Equipment (PPE) Eye/hand/feet/head Protection Respiratory protection Hearing protection 20 Written Safety Plans Typical Topics: Fall Protection Lockout/Tagout Confined Spaces Fire Prevention Welding/Cutting/Brazing Machine Guarding 21 OSHA's Revised Recordkeeping Rule 7

8 Plan Specifics Must be specific to: Company Workplace environment Must be kept current Must be readily available to all employees 22 Mandatory OSHA Poster Post for employees Easily accessible location Replace with updates 23 State Programs Some states operate their own job safety and health programs very similar and comparable rules. 24 OSHA's Revised Recordkeeping Rule 8

9 NOT SURE Where You Are? 25 Where to start? Designate a Safety Manager Provide him/her with technical training and make available continuous technical support Perform complete workplace safety audit (establish current level of compliance) 26 Audit Methods Can be performed by: Internal staff Outside consultant OSHA voluntary visit 27 OSHA's Revised Recordkeeping Rule 9

10 Action Plan Review audit findings Prioritize actionable items (immediately eliminate any imminent danger items) Upon completion of actionable items, continuously perform additional self-audits 28 Safety Program Maintenance Be proactive Gain upper management support Gain employee support And lastly, make it fun! 29 To See Specific Regulations Visit the OSHA web site at: (Don t worry - they don t have surfer ID ) 30 OSHA's Revised Recordkeeping Rule 10

11 For future assistance: Steve Frisch J. J. Keller & Associates, Inc ext Thank You!!! 31 OSHA's Revised Recordkeeping Rule 11