In the United States or if you own a company in the USA OSHA 300 reporting can be a headache for the untrained plus dont forget State Plan Adoption of OSHA’s Revised Reporting Requirements (29 CFR 1904.39) As of August 15, 2016
Plus the new ruling for January of 2017 So how well trained are your staff, are you doing it right and remember the fines for not doing it right went up big time in the USA so you may want to train up before you are charged!
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Osha injury reporting
1. OSHA Injury Reporting
or do you have an exemption
State Plan Adoption of OSHA’s Revised Reporting
Requirements
(29 CFR 1904.39)
As of August 15, 2016
https://www.osha.gov/recordkeeping2014/state_adoption_
table.html
2. 2
Did the employee experience an injury or illness?
Is the injury or illness work-related?
Is the injury or illness a new case?
Does the injury or illness meet the general criteria
or the application to specific cases?
RECORD THE INJURY OR ILLNESS
YES
YES
YES
YES
3. Oh don’t want to do it right no problem
OSHA has that one covered too. The new
penalties will take effect after August 1,
2016.
4. But the law states
OSHA State Plan states must adopt
requirements that are substantially identical to
the requirements in this final rule within 6
months after publication of this final rule.
And to teach this to staff you will need the
instructors guide book and program
https://www.osha.gov/recordkeeping/RKpresen
tations.html
5. Did you and team cover the final ruling
What does the rule require?
• The new rule, which takes effect Jan. 1, 2017, requires
certain employers to electronically submit injury and illness
data that they are already required to record on their
onsite OSHA Injury and Illness forms. Analysis of this data
will enable OSHA to use its enforcement and compliance
assistance resources more efficiently. Some of the data will
also be posted to the OSHA website. OSHA believes that
public disclosure will encourage employers to improve
workplace safety and provide valuable information to
workers, job seekers, customers, researchers and the
general public. The amount of data submitted will vary
depending on the size of company and type of industry.
6. Anti-retaliation protections
The rule also prohibits employers from discouraging
workers from reporting an injury or illness. The final rule
requires employers to inform employees of their right to
report work-related injuries and illnesses free from
retaliation; clarifies the existing implicit requirement that
an employer’s procedure for reporting work-related
injuries and illnesses must be reasonable and not deter or
discourage employees from reporting; and incorporates
the existing statutory prohibition on retaliating against
employees for reporting work-related injuries or illnesses.
These provisions become effective August 10, 2016, but
OSHA has delayed their enforcement until Nov. 1, 2016 in
order to provide outreach to the regulated community.
7. Lets start off with a form or two
• Instructions for Forms 300, 300A, 301
(Instructions ONLY) - PDF Fillable Format
• Forms 300, 300A, 301 (Forms ONLY) - PDF Fillable
Format
• Forms 300, 300A, 301 and Instructions
• Forms 300, 300A, 301 (Forms ONLY)
• Forms 300, 300A, 301 Excel format (Forms ONLY)
Requires Microsoft Excel, Excel equivalent,
free MS Excel Viewer or other file viewers
8. Plus what the law really does state
• https://www.osha.gov/recordkeeping/entryfa
q.html
9. Completing the OSHA Recordkeeping Forms
• Requirement to complete the forms and evaluate specific
exceptions
• The forms in OSHA’s recordkeeping package
• Recordability criteria for injuries and illnesses
• Recording injuries/illnesses on the forms
1 2
A review of the recordkeeping requirements and forms at a
high level:
10. Who has to complete the OSHA injury and illness
recordkeeping forms?
Many but not all employers. Exceptions are based on:
• Small employer exemption – 10 or fewer employees at all
times during the year
• Low-hazard industry exemption – see list of Partially Exempt
Industries (PDF)
Fatality and other serious event reporting as well as injury and
illness surveys involve other considerations.
2 3
11. What forms must be completed?
• OSHA Form 300 – Log of Work-Related Injuries and Illnesses
• OSHA Form 301 – Injury and Illness Incident Report
• OSHA Form 300A – Summary of Work-Related Injuries and
Illnesses
3 4
12. What cases need to be recorded on the forms?
• Injuries and illnesses
• Work related
• Meet certain severity criteria
4 5
13. What is considered an injury or illness?
• An abnormal condition or disorder
• Not an exposure, unless it results in signs or
symptoms
5 6
14. What cases are work related?
6 7
• Cases caused by events or exposures in the work environment
• Cases contributed to by events or exposures in the work
environment
• Cases significantly aggravated by events or exposures in the
work environment
(For a list of activities that are not work related, see section 1904.5(b)(2) [PDF].)
15. What are the severity criteria for recording a work-
related injury or illness?
• Death
• Loss of consciousness
• Days away from work
• Restricted work activity or job transfer
• Medical treatment beyond first aid
7 8
17. OSHA Form 300: Recording a Case with Days
Away From Work
9 10
18. OSHA Form 300: Recording a Case with Restricted
Work Activity or Job Transfer
10 11
19. OSHA Form 300: Recording a Case with Medical
Treatment beyond First Aid
11 12
(For a list of specific treatments considered to be first aid, see section 1904.7(b)(5) [PDF].)
20. Other Recording Criteria
12 13
• Significant diagnosed injury or illness
• Needlestick and sharps injuries – section
1904.8 (PDF)
• Medical removal – section 1904.9 (PDF)
• Hearing loss – section 1904.10 (PDF)
• Tuberculosis – section 1904.11 (PDF)
22. OSHA Form 300A: Summary of Work-Related
Injuries and Illnesses
14 15
23. OSHA Form 300A: Summary of Work-Related
Injuries and Illnesses (continued)
15 16
24. 24
1904.31 – Covered Employees
• Employees on payroll
• Employees not on payroll who are supervised on a
day-to-day basis
• Exclude self-employed and partners
• Temporary help agencies should not record the cases
experienced by temp workers who are supervised by
the using firm
25. Keep the Forms on File
16 17
• File and update for 5 years
• Do not send copies to OSHA unless asked to
do so
• Allow access to the records
(For details on access provisions, see section
1904.35 [PDF] and 1904.40 [PDF].)