Understanding OSHA s Reporting and Recording Requirements and the Decision Making Process. Marianne McGee OSHA Compliance Assistance Specialist

Transcription

1 Understanding OSHA s Reporting and Recording Requirements and the Decision Making Process Marianne McGee OSHA Compliance Assistance Specialist

2 Reporting Fatalities, Hospitalization, etc Work-related fatalities must be reported within 8 hours In-patient hospitalizations must be reported within 24 hours Amputations must be reported within 24 hours Loss of an eye must be reported within 24hours

3 How to Report Fatalities, Hospitalization, etc Call: OSHA or the local OSHA office Go online

4 Who Has To Keep The OSHA 300 Logs?

5 Who Has To Keep The OSHA 300 Logs? Employers with more than 10 employees At all times during the previous calendar year Include temporary employees you supervise on a day to day basis Except certain industries See 1904 Subpart Appendix A

6 300 - Log of Work-related Injuries and Illnesses

7 300A - Summary of Work-related Injuries and Illnesses

8 301 - Injuries and Illness Incident Report

9 What Has To Be Recorded On The OSHA Logs? Work-related incidents resulting in: Death Days away from work Days restricted or a job transfer Medical treatment beyond first aid

10 When? Within 7 days of learning of an injury or illness Must keep the logs for 5 years past the year they cover When requested by OSHA must provide within 4 business hours

11 Electronic Submission of Injury and Illness Data Who, What, When, Where, Why?

12 Who Will Have to Submit This Data? Establishments with employees will be required to electronically submit their OSHA 300, 301, and 300A annually Not related to whether they are a high hazard or a low hazard industry. It s size based Establishments with employees in high hazard industries will be required to electronically submit their OSHA 300A annually. High hazard industry

13 Who are High Hazard Industries? Ag., forestry and fishing (NAICS 11) Utilities (NAICS 22) Construction (NAICS 23) Manufacturing (NAICS 31-33) Wholesale Trade (NAICS 42) Industry groups (4-digit NAICS) with a three year average DART rate of 2.0 or greater in the Retail, Transportation, Information, Finance, Real Estate and Service sectors.

14 Establishment What is an establishment a single physical location where business is conducted or where services or industrial operations are performed. For activities where employees do not work at a single physical location, such as construction; transportation; communications, electric, gas and sanitary services; and similar operations, the establishment is represented by main or branch offices, terminals, stations, etc. that either supervise such activities or are the base from which personnel carry out these activities What about size of a company That s determined by the size of the whole company for the small employer exemption in RK but for the electronic reporting it refers to the size of the establishment

15 Who Submits Data Establishments with Employees Establishments with Employees in High Hazard Industries

16 What About Construction? Construction Sites > 1 Year One log per long term jobsite greater than 1 year. Construction/ Establishments with Short Term Sites Short term jobs can be recorded on 1 log at the main office

17 Example High Hazard Industry Houston office has 251 employees >250 ees Corpus Christi office has 21 employees > 20 ees Laredo office has 19 employees <20 ees

18 What Data Will Have To Be Submitted? Establishments with A (currently under review) Establishments with A annually

19 When Will Data Need To Be Submitted? December 15, 2017

20 Where Will The Data Be Submitted? Injury Tracking Application (ITA) Employers can access the application from the ITA landing page at njuryreporting/index.ht ml

21 Injury Tracking Application (ITA) ITA is a secure website with 3 options for data submission: o Manually enter data into a webform o Upload CSV file to process single of multiple establishments at the same time o Users of automated recordkeeping systems can transmit data electronically via an Application Programming Interface (API)

22 Injury Tracking Application (ITA) The application has a Help Request Form link at the bottom of each page If you have questions concerning any technical or policy aspects of the data collection, please use the Help Request Form to ask your question. That way, OSHA can coordinate our responses and quickly learn of any problems the regulated community may be experiencing with the system.

23 Why Collect This Data? OSHA will be able to better identify small and medium employers who experience high overall injury/illness rates for referral to the OSHCON program Allow OSHA to identify emerging hazards and initiate a response and reach out to employers whose workplaces might include those hazards

24 Why Collect This Data? Allow OSHA to more effectively target enforcement resources to establishments with high rates or numbers of injuries and illnesses and better evaluate its interventions Data will be used for targeting inspections and emphasis programs Enable OSHA to evaluate the impact of government injury prevention activities

25 Recordkeeping Requirements and Forms

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27 Recordkeeping Decision Making Process

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29 No No Did the employee experience an injury or illness? Are there signs and symptoms? Yes Is the injury or illness work related? Work Environment Yes No Do not record the injury or illness Is the injury or illness a new case? Yes Does the injury or illness meet the general recording criteria? Loss of consciousness Update previously recorded injury Yes Record the injury or illness

30 Recordkeeping Decision Making Process 1. Are there signs or symptoms an injury or illness occurred? 2. Was it work-related? Event or exposure in the work environment 3. Is it a new case? 4. Did it result in: Death, days away, restricted work activity, medical treatment beyond first aid, loss of consciousness?

31 Marianne McGee