OSHA Recordkeeping for Seniors Housing

Transcription

1 OSHA Recordkeeping for Seniors Housing (Updated for 2011) Presented by: Scott Bertulis, CSP, ARM Senior Risk Control Consultant

2 Agenda OSHA s National Emphasis Program for Recordkeeping Who should maintain the recordkeeping forms / files? Recordability flow chart First aid vs. medical treatment Required forms (300, 301, 300A) Sharps Injury Log / Bloodborne Pathogens compliance Case Examples using the log OSHA & BLS Surveys OSHA s Site Specific Targeting Program Questions 2

3 OSHA s National Emphasis Program on Recordkeeping The effective date of the current program was September 28, 2010 Based on this NEP, OSHA is completing inspections of companies with low injury and illness rates in high hazard rate industries Companies with reported DART rates between 4.2 & 8.0 on their recordable injury and illness survey regarding the 2008 year are on the inspection list Nursing Care Facilities (NAICS Code ) are the only businesses within Seniors Housing that are included in this Program Inspection Protocols Complete Records Review Interviews with Employees, recordkeeper, management, and health care providers Walkthrough inspection What should you do? Maintain all required OSHA forms (300, 300A, & 301) Correct any deficiencies on forms for at least 3 previous years 3

4 Who Should Maintain the Recordkeeping Forms? Office and/or human resources managers should maintain the OSHA recordkeeping forms at each location Every location should have a primary AND backup person to maintain the logs Cross training should be maintained to ensure that the logs are kept up-to-date when the primary record keeper is off of work for an extended period of time (sickness, maternity leave, medical leave of absence, etc.) The backup record keeper must replace the primary record keeper if he/she leaves the company for any reason. 4

5 How do I know if an Employee injury or illness is recordable? Employee has injury or illness Is the case work related? No Not Recordable Yes Lost or Restricted Days? Yes Recordable No Not Recordable 1 st Aid Medical Treatment or First Aid? Medical Treatment Recordable 5

6 Medical Treatment (recordable) Medical treatment is the management and care of a patient to combat disease or disorder It does not include: Visits to a PLHCP solely for observation or counseling Diagnostic procedures First aid If a doctor prescribes prescription medication(s), it is considered to be medical treatment and is recordable If the injured employee receives sutures to close a wound, it is considered medical treatment and is recordable 6

7 First Aid (not recordable) Using nonprescription medication at nonprescription strength Ibuprofen (such as Advil )-Less than 467 mg Diphenhydramine (such as Benadryl )-Less than 50 mg Naproxen Sodium (such as Aleve )-Less than 220 mg Ketoprofen (such as Orudus KT )-Less than 25mg Tetanus immunizations Cleaning, flushing, or soaking surface wounds Wound coverings, butterfly bandages, Steri-Strips Hot or cold therapy Non-rigid means of support Temporary immobilization device used to transport accident victims -Continued on Next Slide- 7

8 First Aid (not recordable) Drilling of fingernail or toenail, draining fluid from blister Eye patches Removing foreign bodies from eye using irrigation or cotton swab Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means Finger guards Massages Drinking fluids for relief of heat stress 8

9 Recordkeeping Forms Required OSHA Forms 300 Log 300A Summary Report 301 Form or Equivalent Employers must enter each recordable case on the 300 log and a 301 form (or equivalent form) within 7 calendar days of receiving information that the case is recordable The OSHA 300A must be completed and posted every year from February 1 st through April 30 th 9

10 Bloodborne Pathogens Exposures to Bloodborne Pathogens are recordable, as follows: All needle sticks with used needles are recordable All cuts from blood contaminated sharp objects (i.e. broken glass) are recordable Diagnosed illnesses from exposure to blood or OPIM splashes are recordable All contaminated sharps injuries (i.e. needle stick) must also be recorded on a separate Sharps Injury Log 10

11 Privacy Protection Privacy concern cases are: An injury or illness to an intimate body part or reproductive system An injury or illness resulting from sexual assault Mental illness HIV infection, hepatitis, tuberculosis Needle sticks and sharps injuries contaminated with another person s blood or other potentially infectious material Employee voluntarily requests to keep name off for other illness cases 11

12 Case Example Demonstrations Combined Example 1. Lost workday case 2. New vs. Existing case 3. New vs. Existing case 4. Restricted workday case (i.e. transitional duty) 5. Combination lost and restricted workday case 6. Case that involves over 6 months of days away and/or restricted days 7. Other recordable case without days away or restricted days prescription meds 8. Privacy concern case (sharps injury log also used) 9. Case that carries over to the following year (i.e. injury date 12/29, with 3 months lost time) 12

13 OSHA Recordkeeping Files By law, you must maintain recordkeeping forms for the current year and five previous years To be prepared in the event of an OSHA inspection, a recordkeeping file should be maintained for each year that includes the following: OSHA 300 log OSHA 301 forms or equivalent state first report of injury form provided by TPA or WC Carrier OSHA 300A form (after the calendar year is complete) Copies of return-to-work status reports Copies of doctor s notes indicating medical treatment beyond first aid (i.e. sutures, prescription meds, broken bones, etc.) 13

14 OSHA & BLS Surveys Annual OSHA Survey Determines if you meet the criteria for Site Specific Targeting Plan (see following slides) Immediately contact your Risk Management Department or Safety Director if you receive a survey in the mail You must send the completed report to OSHA within 30 calendar days or by the date stated in the survey For more info, visit the following web address Annual BLS* Survey Used to create the Nation s occupational injury and illness statistics No impact on OSHA SST program inspections *Bureau of Labor Statistics 14

15 Site Specific Targeting (SST) Program for Seniors Housing This program targets for inspection those industries with high injury and illness rates. The current program became effective on August 18, 2010 and is set to expire on August 18, 2011 or until replaced earlier by a new notice Seniors Housing impact: Only considered for this targeting subset if your location reported under SIC codes starting with 805 Nursing & Personal Care Facilities The current trigger for inspection is a reported DART rate of 16.0 or higher or a DAFW rate of 13.0 or higher on an OSHA survey regarding the 2008 calendar year Surveys asking for 2008 calendar year data were sent out in early to mid Continued on Next Slide- 15

16 DART & DAFW Rate Examples Example Experience for 2008 Log 6 Total Recordable Cases 5 DART (Days Away, Restricted, or Transferred) Cases Of the 5 DART cases, 2 were involved days away from work, resulting in 2 DAFW Cases 1 Other Case 125,000 Total Hours Worked in DART Rate- DART Rate =No. of DART Cases X 200,000 Total Hours Worked DART Rate = 5 X 200, ,000 DART Rate = 8.0 -DAFW Rate- DAFW Rate = No. of DAFW Cases X 200,000 Total Hours Worked DAFW Rate = 2 X 200, ,000 DAFW Rate =

17 Questions If you have questions about recordability or would like to download OSHA s Recordkeeping forms or the OSHA Recordkeeping Handbook, go to: qhttp:// Recommended recordkeeping software qwww.gneil.com (search Gradience OSHA Manager Software - $209) qwww.jjkeller.com (search OSHA Recordkeeping Software - $199) If you have additional questions about recordability or lost, restricted, or transferred days, me at scott.bertulis@willis.com 17