Most businesses will need to post their OSHA Form 300A from Feb. 1 through April 30. This document communicates with your people your OSHA recordable incidents for the previous year — that's work-related injuries and illnesses. Failure to meet this requirement could result in big fines for your organization. Also, unprecedented upcoming OSHA regulations may require you to submit your company's OSHA 300 log information directly to OSHA- how might this impact you?
With OSHA's final ruling on requiring employers submit injury and illness data electronically, significant changes will need to be implemented by the effective date of December 1, 2016 to ensure compliance in this changing area.
This webinar will touch on when you must submit your electronic records to OSHA, the implications of OSHA posting your injury records, and how the new ruling impacts your reporting procedures and employee accountability.
4. Objectives of Training
• OSHA UPDATES!
• Do I record or do I not record?
• Which forms do I use?
• How to fill them out
• Where to put them after completion
• What’s considered an OSHA recordable?
• What’s considered first aid?
• Filing requirements
6. “Improved” Tracking of Workplace
Injuries and Illnesses
• Data will also be posted to the
OSHA website and made public.
• Employee count is based on
location
• Anticipate striking the “or
equivalent form”
oWC forms may not be
acceptable for 301’s All submissions must be done electronically!
7. Drug Testing: OSHA Stance
“The rule does not prohibit drug testing of employees. It only prohibits employers
from using drug testing, or the threat of drug testing, as a form of retaliation against
employees who report injuries or illnesses..”
9. OSHA Area Office P.O.C.
Contact the office nearest the incident.
• Appleton Area Office
1648 Tri Park Way
Appleton, Wisconsin 54914
(920) 734-4521
(920) 734-2661 FAX
• Eau Claire Area Office
1310 W. Clairemont Avenue
Eau Claire, Wisconsin 54701
(715) 832-9019
(715) 832-1147 FAX
• Madison Area Office
4802 E. Broadway
Madison, Wisconsin 53716
(608) 441-5388
(608) 441-5400 FAX
• Milwaukee Area Office
310 West Wisconsin Avenue, Room 1180
Milwaukee, Wisconsin 53203
(414) 297-3315
(414) 297-4299 FAX
https://www.osha.gov/html/RAmap.html
10. OSHA Must Be Notified…. What’s Next?
• Rapid response investigations (RRI)
oQuestions OSHA WILL ask
oOSHA’s triaging once reported
• Root cause analysis with documented evidence
• What may trigger an inspection?
12. How do I Know If I Need to Record This Info?
• 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 based on North American Industrial
Classification System (NAICS) code.
o Retail only
o Insurance firms
o Banks
o Etc.
13. 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
14. What Criteria Must be Met to be Considered
an OSHA Recordable Injury/Illness?
• Injuries and illnesses
• Work related
• Meet certain severity criteria
15. What Exactly is an Injury or Illness?
• An abnormal condition or disorder
• Fractures
• Sprains
• Respiratory conditions
• Symptoms of…
• Not an exposure, unless it results in
signs or symptoms
• Observations or diagnostics only…
16. Work Relatedness
• 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
What do you think: Work-related
injury in the works?
Any contribution to the injury!
17. What’s NOT Work Related?? 1904.5(b)(2)(i-vi)
• The incident happens at work but is the result
solely from a non-work-related event or exposure
• Voluntary participation in a wellness program
• Eating, drinking, or preparing food
• Mental Illness (unless a qualified person
determines it is work related)
• Establishes a “Home-Away-From-Home”
Work Related
Non-Work
Related*
18. Other Considerations for By-Mile Employees
• Injuries experienced while driving a truck route or while
loading or unloading, is considered work related for OSHA
recordkeeping purposes
• Sleeper berth injuries are not considered work related
• Injuries in a motel or hotel are not considered work
related.
• Any injury or illness experienced while stopped for
eating/bathing are not considered work related.
19. Severity Requirement
• Death
• Loss of consciousness
• Days away from work
• Restricted work activity or job transfer
• Medical treatment beyond first aid*
• Prescription grade medication
20. What is Considered First Aid?
• Non-prescription medication at non-prescription strength
• Tetanus immunizations
• Cleaning, flushing, soaking superficial wounds
• Wound coverings
• Hot or cold therapy
• Non-rigid supports
• Temporary immobilization devices
• Drilling fingernails
• Eye patch
• Simple irrigation or use of cotton swab to remove foreign material from eye (not embedded)
• Splinters that can be removed with tweezers (exception: eye)
21. FAQs
• When do I start counting days?
• Day 1 on the log = Day 2 of the injury
• What if an employee has been restricted but still elects to work anyway?
• Always encourage employees to follow physician recommendations
• If the employee insists, these days are still considered days away
• An employee is cleared to work but does not want to come back.
• As-soon-as the physician states the employee can return to work the following days are no
longer counted as days away but may be restricted/transfer days
• An employee was hurt on Friday and returns to work the following Friday, how many days
away is this?
• Days are counted on a calendar basis, this would be 6 days away
• If employee returns on Monday, and the physician indicated that the employee should not
have worked the weekend these days are also counted.
22. OSHA Injury and Illness Form
https://www.osha.gov/recordkeeping/RKform300pkg-fillable-enabled.pdf
23. The OSHA 300 Log
• Maintained all
year…
• Injury no loss time
• Injury loss time
oHow to calculate
days
oType of injury
• Restricted or
reserved
• Digital 300 Logs
32. 300 300a Wrap Up
• What did we cover again??
o OSHA update
o Exceptions to the standard
o Forms Overview
300
300a
301
o What’s considered an OSHA recordable event
o Detailed steps on completion of forms