OSHA INJURY AND ILLNESS RECORDKEEPING 1
POP QUIZ True or False All Workers Comp cases are OSHA Recordable? 2
ANSWER : Cases are OSHA recordable Only IF they meet the OSHA requirements. 3
OSHA INJURY AND ILLNESS RECORDKEEPING 5 STEP PROCESS 4
Step 1 Did the employee experience an injury or illness? If so, go to Step 2 5
Step 2 Is the injury or illness work-related? If so, go to Step 3 6
Step 3 Is the injury or illness a new case? If so, go to Step 4 7
Step 4 Does the injury or illness meet the general criteria or the application to specific cases? If so, go to Step 5 8
Step 5 Record the Injury or illness. 9
Step 1: Did the employee experience an injury or illness? 10
Scenario 1: A CNA reports to nurses station with complaint of painful wrists. Employee given 2 Advil and returned to job. Is this an injury? 11
Scenario 2: There is a gas leak at your facility and the two (2) employees in the area are rushed to the hospital. They are told to stay home the next day as a precautionary measure. Is this an injury? 12
Step 2: Is the injury or illness work-related? 13
Determination of work-relatedness You must consider an injury or illness to be 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. 14
The following situations are not work-related: There is no discernable cause. 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. 15
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. 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. 16
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 employer s premises or brought in). For example, if the employee is injured by choking on a sandwich while in the employer s establishment, the case would not be considered work-related. 17
The following situations also are not work-related: The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee s 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. 18
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. The illness is the common cold or flu (Note: contagious diseases such as tuberculosis, brucellosis, hepatitis A, or plague are considered workrelated if the employee is infected at work). 19
The illness is a mental illness. Mental illness will not be considered workrelated unless the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related. 20
Scenario 1: Employee sprains ankle walking across facility parking lot on way in to work. Is this work related? 21
Scenario 2: Employee is hit by car in facility parking lot on way in to work, injures ribs. Is this an injury? 22
Scenario 3: Employee falls out of car in facility parking lot on way in to work injuring knee. Is this an injury? 23
Scenario 4: Employee gives blood at voluntary employer sponsored blood drive and passes out losses consciousness. Is this work related? 24
Scenario 5: Employee slips and falls in facility hallway while picking up pay check. Is this work related? 25
Scenario 6: Employee slips on dining room floor while sitting down to eat lunch. Is this work related? 26
Step 3: Is the injury or illness a new case? 27
Determination of a 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, OR the 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) from the previous injury or illness and an event or exposure in the work environment caused the signs or symptoms to reappear. 28
Scenario 1: Five (5) weeks ago, CNA 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 resident. Is this a new case? 29
Scenario 2: Five (5) weeks ago CNA 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 throughout this period of time. Is this a new case? 30
Step 4: Does the injury or illness meet the general criteria or the application to specific cases? 31
You must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, if it results in any of the following: death days away from work restricted work or transfer to another job medical treatment beyond first aid loss of consciousness 32
DAYS AWAY FROM WORK Count the number of calendar days the employee was away from work or restricted/transferred (include weekend days, holidays, vacation days, etc.) May cap day count at 180 days away and/or days restricted May Stop 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 33
Medical Treatment VS First Aid Medical treatment DOES NOT include: 1. Visits to a physician or other licensed health care professional solely for observation or counseling only 2. 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) 3. First Aid 34
Medical Treatment VS First Aid cont d. 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 - Removing foreign bodies from the eye using only irrigation or a cotton swab is 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 35
Medical Treatment VS First Aid cont d. - Using any non-rigid means of support, as elastic bandages, wraps, back belts, etc. is First Aid - 1 dose prescription med is Medical Treatment - Over the Counter non-prescription med at non-prescription strength is First Aid OTC med 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 - Administering tetanus immunizations is First Aid - Cleaning, flushing or soaking wounds on the surface of the skin is First Aid - Using wound coverings such as Band-Aids; Butterfly bandage/steri-strip (the only kind of wound closures) are First Aid - Any number of hot-cold treatments is First Aid 36
Relationship to Bloodborne Pathogen Standard Needlesticks and sharps injuries 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 Employers may elect to use the OSHA 300 and 301 forms to meet the sharps injury log requirements, provided two conditions are met: 1 The employer must enter the type and brand of the device on either the 300 or 301 form. 2 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. 37
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. Equivalent: First Report of Injury with reference to OSHA 300 Log case number 38
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1904.29 - Forms Employers must enter each recordable case on the forms within 7 calendar days of receiving information that a recordable case occurred An equivalent form has the same information, is as readable and understandable, and uses the same instructions as the OSHA form it replaces Forms can be kept on a computer as long as they can be produced when they are needed (i.e., meet the access provisions of 1904.35 and 1904.40) Certification by THE senior establishment management official on OSHA 300 A Summary Form 42
Covered Employees: You must record on the OSHA 300 Log the recordable injuries and illnesses of all employees on your payroll, whether they are labor, executive, hourly, salary, part-time, seasonal, or migrant workers. You also must record the recordable injuries and illnesses that occur to employees who are not on your payroll if you supervise these employees on a dayto-day basis. 43
For More Help on OSHA Recordkeeping OSHA s Recordkeeping Pagehttp://www.osha.gov/recordkeeping/index.html 44
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