# Presentation: 099275

## OSHA INJURY AND ILLNESS RECORDKEEPING	

**Part 1904 Basics for Federal Agencies**
**Bob Whitmore **

## 	    OSHA INJURY AND ILLNESS RECORDKEEPING	

## 1904 for Federal Agencies took effect 1/1/2005

- 2005 is a “transition” year...OSHA won’t enforce regulation.
- 1/1/2006 OSHA can begin enforcement ... we obviously will be looking at 2005 Logs etc.... SO...use this year to produce accurate, complete 2005 records !!

## POP QUIZTrue or False

- All Workers Comp cases are OSHA Recordable ?

## ANSWER :

**I have NO Clue !!!**
**Cases are OSHA recordable** **Only IF** **they meet the OSHA requirements.**

## WARNING  !!!

- IF YOU ARE HERE TO LEARN OR DISCUSS Workers Comp. You are in the Wrong Room !!!!
- OSHA Recordkeeping and Workers Comp. are totally Unrelated Systems !!

## 2nd WARNING:  DO NOT MIXOSHA RECORDABILITY AND WORKERS’ COMPENSATION 

- Workers’ Compensation determinations do NOT impact OSHA recordability.
- 	Some cases may be OSHA recordable and   compensable.
- 	Some cases may be compensable, but not  OSHA recordable.
- 	Some cases may be OSHA recordable, but not compensable.

## 	    OSHA INJURY AND ILLNESS RECORDKEEPING	

**	****	****	****5 STEP PROCESS**

## YES

- experience an
- injury or illness?

- Does the injury or illness meet
- the general criteria or the
- application to specific cases?

**Record the **
**Injury or illness.**

***YES***

***YES***

***YES***

***YES***

## 1904.46      Did the employee experience an injury or illness?            STEP 1

## Injury or illness. An injury or illness is an abnormal condition or disorder. Injuries include cases such as, but not limited to, a cut, fracture, sprain, or amputation. Illnesses include both acute and chronic illnesses, such as, but not limited to, a skin disease, respiratory disorder, or poisoning. (Note: Injuries and illnesses are recordable only if they are new, work-related cases that meet one or more of the Part 1904 recording criteria.) 

- Did the employee
- experience an
- injury or illness?

***Injury or illness.*** An injury or illness is an abnormal condition or disorder. Injuries include cases such as, but not limited to, a cut, fracture, sprain, or amputation. Illnesses include both acute and chronic illnesses, such as, but not limited to, a skin disease, respiratory disorder, or poisoning. (Note: Injuries and illnesses are recordable only if they are new, work-related cases that meet one or more of the Part 1904 recording criteria.)

**Notes:**
Do you want Answer and Why to be seen together or enter separate?

## 	A worker reports to nurses station with complaint of painful wrists.  Employee given 2 AdvilTM and returned to job.

- Did the employee
- experience an
- injury or illness?

**Stop Here **
**OR **
**Go On To The Next Step?**

**Scenario A:**
- 	A worker reports to nurses station with complaint of painful wrists.  Employee given 2 AdvilTM and returned to job.

**Answer:****	****Go on to the next step.**

**Why:****	****Painful wrists was the injury experienced.**

**Notes:**
Do you want Answer and Why to be seen together or enter separate?

- 	There is a chlorine gas leak at XYZ establishment 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.

**Step 1:**
- Did the employee
- experience an
- injury or illness?

**Stop Here **
**OR **
**Go On To The Next Step?**

**Answer:****	****It depends ! !  We need more information.**

**Why:****  ****We need to know if either employee exhibited signs or symptoms ****	****of an injury/illness.  If yes, then go to the next step.  If no, STOP.  We have an event or exposure only.**

## YES

- experience an
- injury or illness?

***YES***

## Step 2:

- Is the injury or
- illness work-related?

**	****	**** ****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.

## 	The following situations are not work-related:

- 1.      There is **no** _discernable cause__. _ Injury/illness did not result from event/exposure at work.

- 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.

- 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.

- 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.

**Note****:  **If the employee is made ill by ingesting food contaminated by
-             workplace contaminants (such as lead), or gets food poisoning
-             from food supplied by the employer, the case would be
-             considered work-related.

## 	The following situations also are not work-related:

- 	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.

- 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 a mental illness.  Mental illness will not be considered work-related 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.

- The illness is the common cold or flu (Note: contagious diseases such as tuberculosis,
- 	brucellosis, hepatitis A, or plague are considered work-related if the employee is infected
- 	at work).

**	****The following situations also **_**are not work-related**_**:**

## 3rd WARNING:  DO NOT MIXOSHA RECORDABILITY AND WORKERS’ COMPENSATION 

- Workers’ Compensation determinations do NOT impact OSHA recordability.

## Why?:	Exception #4 -  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. 

**OR**
**Go On To The Next Step?**

**Why?:****	****Exception #4 -  **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.** **

**Step 2:**
- Is the injury or
- illness work-related?

**Scenario A:**
- 	Employee gives blood at voluntary employer sponsored blood drive and passes out – losses consciousness.

**Answer:****	****Stop Here**

## 	Employee sprains ankle in company parking lot on way in to work. 

- 	Employee sprains ankle in company parking lot on way in to work.

**Step 2:**
- Is the injury or
- illness work-related?

**Stop Here**
**OR**
**Go On To The Next Step?**

**Why?:****	****There is no exception that applies****.**

**Answer:****	****Go on**

## Why?:	Exception #6 - 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.

- 	Employee slips and falls in hallway while working on daughter’s science project on Saturday, employee’s day off.

**Step 2:**
- Is the injury or
- illness work-related?

**Stop Here**
**OR**
**Go On To The Next Step?**

**Why?:****	****Exception #6 - **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.

**Answer:****	****Stop**

## YES

- experience an
- injury or illness?

***YES***

***YES***

## Step 3:

- Is the injury or
- illness a new case?

**	****	**** ****	****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.**

## Scenario A:  Five (5) weeks ago, employee 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.

- Is the injury or
- illness a new case?

**Stop Here**
**OR**
**Go On to the Next Step?**

**Scenario A:  **Five (5) weeks ago, employee 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.

**Why?:****	**Employee was back at normal job and no criteria for recordability was in existence at that time.

**Answer:****	****Go on**

## Scenario B:  Five (5) weeks ago employee 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.  

**Step 3:**
- Is the injury or
- illness a new case?

**Stop Here**
**OR**
**Go On to the Next Step?**

**Why?:****	**Update the previously recorded injury or illness entry if necessary.

**Answer:****	****Stop**

## 1904.7  Does the injury or illness 

- experience an
- injury or illness?

- 1904.7  Does the injury or illness
- meet the general criteria or the
-                    application to specific cases?        STEP 4

***YES***

***YES***

***YES***

## Step 4:

**Step 4:**
- Does the injury or illness
-  meet the general criteria
- or the application
- to specific cases?

**	****	****	**** ****General Recording Criteria**
**	**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, or loss
- 	of consciousness.  You must also consider a case to meet the general
- 	recording criteria if it involves a significant injury or illness diagnosed
- 	by a physician or other licensed health care professional, even if it
- 	does not result in death, days away from work, restricted work or
- 	job transfer, medical treatment beyond first aid, or loss of
- 	consciousness.

-                       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

## Restricted Work Activity – “Fine Points”

- Restriction/transfer limited to day of injury/illness onset _not_ recordable-includes employee being sent home during shift.
- Production of _fewer_  goods or services _not_ considered RWA
- Vague restrictions from physician or LHCP (e.g., “light duty” or “take it easy for a week”) are to be recorded as RWA if no further information is obtained.

## Medical Treatment VS First Aid

**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

## Medical Treatment VS First Aid – cont’d.

- Using eye patches is First Aid

- -	Drilling a nail is First Aid

**Medical Treatment **_**VS**_** First Aid – cont’d****.**

- 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

- First Aid list is comprehensive.  Any other procedure is medical treatment.

- -	Drinking fluids for relief of heat stress is First Aid

## Medical Treatment VS First Aid – cont’d.

**Medical Treatment **_**VS**_** First Aid – cont’d.**

- 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 AdvilTM)                     -      Greater than 467 mg
- 	Diphenhydramine (such as BenadrylTM)    –      Greater than 50 mg
- 	Naproxen Sodium (such as AleveTM)         –      Greater than 220 mg
- 	Ketoprofen (such as Orudus KTTM)           –      Greater than 25 mg

- Any number of hot-cold treatments  is First Aid

- Using wound coverings such as Band-Aids; Butterfly bandage/Steri-Strip (the only kind of wound closures)  are First Aid

- -	Cleaning, flushing or soaking wounds on the surface of the skin is First Aid

- Administering **tetanus** immunizations is First Aid

- Using any non-rigid means of support, as elastic bandages, wraps, back belts, etc. is First Aid

## Significant diagnosed Injury or Illness that is automatically recordable if work related: 				1904.7(b)(7)

**1.****	****Fracture of bones or teeth**

**2.****	****Punctured ear drum**

**3.****	****Cancer**

**4.****	****Chronic irreversible disease  (e.g., silicosis)**

## YES

- experience an
- injury or illness?

- Does the injury or illness meet
- the general criteria or the
- application to specific cases?

**Record the **
**                ****Injury or illness      ****STEP 5**** **

***YES***

***YES***

***YES***

***YES***

## 	Hearing Loss Recordability  1904.10

- OSHA’s recordkeeping rule requires the employer to record all work-
- related hearing loss cases that meet BOTH of the following conditions
- on the same audiometric test for either ear:

- The employee has experienced a Standard Threshold Shift (STS)
- The employee’s total hearing level is 25 dB or more above
- 	audiometric zero (averaged at 2000, 3000, & 4000 Hz) in the
- 	same ear(s) as the STS.

## No

- Use this **‘decision tree’** to determine whether the results of a audiometric exam given on or after January 1, 2003 reveal a recordable STS.

- Note:   In all cases, use the most current baseline to determine recordability as you would to calculate
- a STS under the hearing conservation provisions of the noise standard (§1910.95).  If an STS  occurs in only one ear, you may only revise the baseline audiogram for that ear.
- * The audiogram may be adjusted for presbycusis (aging) as set out in 1910.95.

**No**

**No**

**No**

**Yes**

**Yes**

**Yes**

## Example 1 – Employee A

- 	        **Right ear**		_**2000 Hz**_**	****	**_**3000 Hz**__**	**_**	**_**4000 Hz**_

- Current Test			   10		   15		   15

- Current Baseline		    	     5		   10		     5

- Threshold Shift		     	     5		     5		   10
- Avg. Threshold Shift		(5+5+10)/3 = 6.7 dB

**Since the average threshold shift is less than 10 dB, this employee has not experienced a STS.  This case is not recordable, since experiencing a STS is one of the conditions for recordability.**
***Threshold shifts are determined by subtracting the current baseline from the current test.****	*

## Current Baseline	       	        5		      10		         5		

**	****        ****Right ear **

_**2000 Hz**__**	**__**	**__**3000 Hz**__**	**__**	**__**4000Hz**_

- Current Test		      10		      20		       20

- Current Baseline	       	        5		      10		         5

- Threshold		        5		       10		        15

- Avg. Threshold Shift		(5+10+15)/3 = 10 dB

**Since the avg. threshold shift is 10 dB, this employee has**
**experienced a STS. *Now look at the Total Hearing Level**

**Total Hearing Level**

_**2000 Hz**__**	**__**	**__**3000 Hz**__**	**__**	**__**4000 Hz**_

- Current Test			10		20		20

- Avg. Total Hearing Level	(10+20+20)/3 = 16.7 dB

**This case is not recordable since both conditions for recordability**
**were not met. Even though this employee has experienced a STS,**
**the avg. total hearing level is less than 25 dB above audiometric 0**

## Example 3 – Employee C

**	****        ****Right ear**

_**2000 Hz**__**	**__**	**__**3000 Hz**__**	**__**	**__**4000 Hz**_

- Current Test			15		25		35

- Current Baseline		 	  5		10		  5

- Threshold Shift			10		15		 30

- Avg. Threshold Shift		(10+15+30)/ = 18.3 dB

**Since the avg. threshold shift is greater than 10 dB, this employee **
**has experienced a STS.  * Now look at the Total over all Hearing Level**

_**Total Hearing Level**_

_**2000 Hz**__**	**__**	**__**3000 Hz**__**	**__**	**__**4000 Hz**_

- Current Test			15		25		35

- Avg. Total Hearing Level	(15+25+35)/3 = 25 dB

**This case is recordable since both conditions for recordability have **
**been met on the same test.  This employee has experienced a STS **
**and the avg. total hearing level is 25 dB or more above audiometric 0.**

## Relationship to Bloodborne Pathogen Standard

- Employers _**may elect**_ to use the OSHA 300 and 301 forms to meet the sharps injury log requirements, _**provided two conditions are met**_:
- The **employer must enter the ****type and brand of the device**** on either the 300 or 301 form**.
- 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**.

- 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

## 1904.29 - 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*

## Slide 42

## Slide 43

## Slide 44

## 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

## 	        Other Recording Issues

- 	        **Other Recording Issues**
***1904.31   Covered Employees***
***Basic requirement.*** 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 day-to-day basis.** If your business is organized as a sole proprietorship or partnership, the owner or partners are not considered employees for recordkeeping purposes.

## Still Other Recording Issues

- TB – Positive skin test recordable when known work place exposure to active TB disease.  NO presumption of work relationship in any industry.
- MSD recordable when General Recording Criteria is met.

## For More Help on OSHA Recordkeeping

- OSHA’s Recordkeeping Page-
- http://www.osha.gov/recordkeeping/index.html
- OSHA Regional Recordkeeping Coordinators
- For any help on Workers Comp please **do not**
- call OSHA Recordkeeping .......

## Slide 49