OSHA's Updated Recordkeeping Standard
OSHA’s UpdatedRecordkeeping Standard:What to Report & Record in 2019 .Jack Fearing, CPEA
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsPresentation Outline Purpose and Scope* Forms and Records The Recording Criteria Employee Access & Involvement Record Retention & Updating 2019 Electronic Submission Requirements “Bulletproofing” your records Summary / Q&A*Effective January 1, 20152 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsDisclaimerDue to the constantly changing nature of governmentregulations, it is impossible to guarantee the total andabsolute accuracy of the material contained herein orpresented. Fearing International Group LLC (FIG) cannotand does not assume any responsibility for omissions, errorsor ambiguity contained and will not be held liable in anydegree for any loss, damage or injury caused by any suchomission, error or ambiguity present. It is made available withthe understanding that FIG is not engaged in rendering legal,accounting or professional service in this presentation. If legaladvice is required, the services of such a professional shouldbe sought.3 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsPurpose & ScopeTo require employers to recordand report work-relatedfatalities, injuries and illnesses: All Employees on payroll Employees not on payroll butwho are supervised on a dayto-day basisNote: Recording or reporting a work-related injury, illness, orfatality does not mean the employer or employee was at fault,an OSHA rule has been violated, or that the employee is eligiblefor Workers’ Compensation or other benefits.4 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.5 – Work EnvironmentContractors & Temporary Workers Contractor supervises employee on aday-to-day basis: Contractor records You supervise contractor on a day-today basis: You record on your Form 300One or the other, never both!5 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsIndustry Exemptions* All industries in construction, manufacturing, transportation,maritime, agriculture, utilities and wholesale trade sectorsare still required to complete all three required forms The revised rule updates the industries that are exemptfrom the requirements due to relatively low I&I rates (StatePlans may differ)*Effective January 1, 20156 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsPartially Exempt*Table 1: New List of Partially Exempt IndustriesNAICS**7aTitle of NAICS Code4431Electronics and Appliance Stores4481Clothing Stores5412Accounting & Tax Preparation Services5417Scientific Research & Development Services6214Outpatient Care Centers6215Medical & Diagnostic Laboratories7213Rooming and Boarding Houses*Effective January 1, 2015**North American Industry Classification System
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsNo Longer Exempt*Table 2: Industries Newly Required to Keep RecordsNAICS**7bTitle of NAICS Code4411Automotive Dealers4453Beer, Wine & Liquor Stores5311Lessors of Real Estate5324Commercial & Industrial Machinery Rental6219Other Ambulatory Healthcare Services7121Museums, Historical Sites & Similar Institutions7139Other Amusement & Recreation Industries*Effective January 1, 2015**North American Industry Classification System
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.29 - FormsRecordkeeping Forms OSHA Form 300, Log of WorkRelated Injuries and Illnesses OSHA Form 300A, Summary ofWork-Related Injuries and Illnesses OSHA Form 301, Injury and IllnessIncident Report8 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaThe Recording CriteriaCovered employers must record each fatality, injury or illnessthat: Is work-related, and/or Is a new case, and/or Meets one or more of the criteria contained in1904Note: Employers must enter each recordable case on the form within 7calendar days of receiving information that a recordable case occurred9 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaThe Recording Criteria10 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaMedical TreatmentMedical treatment is the management and care of a patient to combatan injury, disease or disorder It does not include: Visits to a PLHCP* solely for observation or counseling Diagnostic procedures First aid*Physician or Licensed Health Care Professional11 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsFirst Aid Using nonprescription medication at nonprescriptionstrength Tetanus immunizations Cleaning, flushing, or soaking surface wounds Wound coverings, butterfly bandages, Steri-Strips Hot or cold therapy Non-rigid means of support Temporary immobilization device used to transportaccident victims Many others12 1.908-303.8359 FLEMINGTON, NJ1904.7 (b) (5)
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaThe Recording Criteria13 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.5Work Environment The Work Environment is defined as the establishment andother locations where one or more employees are workingor present as a condition of employment. The Work Environment includes not only physical locations,but also the equipment or materials used by employeesduring the course of their work.14 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaSignificant Diagnosed Injury/IllnessThe following work-related conditions must always berecorded at the time of diagnosis by a PLHCP: Cancer Chronic irreversible disease Punctured eardrum Fractured or cracked bone or tooth15 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaWork at HomeInjuries and illnesses that occur while an employee is working athome are work-related if they: Occur while the employee is performing work for pay orcompensation in the home Are directly related to the performance of work rather than thegeneral home environment16
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.5Travel Status An injury or illness that occurs whilean employee is on travel status iswork-related if it occurred while theemployee was engaged in workactivities in the interest of theemployer Home away from homeNote: Detours for personal reasons are not work-related.17 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.5 – Work-RelatednessRecording Exceptions: Present as a member of the general public Symptoms arising in work environment that aresolely due to non-work-related event or exposure Voluntary participation in wellness program,medical, fitness or recreational activity Eating, drinking or preparing food or drink forpersonal consumption Motor vehicle accident in parking lot/access roadduring commute18 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaThe Recording Criteria19 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaNew Cases If there is a medical opinion regardingresolution of a case, the employer mustfollow that opinion If an exposure triggers the recurrence, itis a new case (e.g., asthma, rashes) If signs and symptoms recur even in theabsence of exposure, it is not a newcase (e.g., silicosis, tuberculosis,20asbestosis) 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaSignificant AggravationA pre-existing injury or illness is significantly aggravated whenan event or exposure in the work environment results in any ofthe following (which otherwise would not have occurred): Death Loss of consciousness Days away, days restricted or job transfer Medical treatment211.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaThe Recording Criteria22 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaAdditional Criteria Loss of Consciousness Medical Removal Job Transfer Bloodborne Pathogens Tuberculosis Hearing Loss23 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.7 – General CriteriaHearing LossYou must record all work-related hearing loss cases where: Employee has experienced a Standard Threshold Shift(STS), and Employee’s hearing level is 25 decibels (dB) or moreabove audiometric zero [averaged at 2000, 3000, and4000 hertz (Hz)] in the same ears as the STSNote: An STS is defined in OSHA’s noise standard at 29 CFR 1910.95(g)(10)(i) as a change inhearing threshold, relative to the baseline audiogram, of an average of 10 dB or more at2000, 3000, and 4000 Hz in one or both ears 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsFilling Out the “Log”(A) (B) (C)Case No.EE NameJob Title(D) (E) (F)Date of EventLocationDescription1904.29 - Forms(G) (H) (I) (J)ChooseONLYone(M) (1-6)ChooseONLYone(K) (L)EnterCalendar DaysRecommendBy the PLHCP.Note: A combination ofeither or both caps at180 days. 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsRecording a Fatality 1.908-303.8359 FLEMINGTON, NJ1904.29 - Forms
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsDays Away from Work Case 1.908-303.8359 FLEMINGTON, NJ1904.29 - Forms
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsRestricted Activity Case 1.908-303.8359 FLEMINGTON, NJ1904.29 - Forms
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsMedical Treatment Case 1.908-303.8359 FLEMINGTON, NJ1904.29 - Forms
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsOSHA Form 30130 1.908-303.8359 FLEMINGTON, NJ1904.29 - Forms
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsOSHA Form 300 1.908-303.8359 FLEMINGTON, NJ1904.29 - Forms
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.29 - FormsFrom 300 (Cont.) 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.29 - FormsCertifying & Posting the Annual Summary Completed & certified by an authorized member ofmanagement Posted no later than February 1st Kept in place until April 30th 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsUse of Technology An equivalent form may be used if ithas the same information, is asreadable and understandable, anduses the same instructions as the OSHAform it replaces Forms can be kept on a computer aslong as they can be produced whenthey are needed (i.e., meet the accessprovisions of 1904) 1.908.303.8359 FLEMINGTON, NJ1904.29 - Forms
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.39Severe Injury/Illness Reporting Employers must report: All work-related fatalities:Within 8 hours All work-related in-patient hospitalization:Within 24 hours Amputations Losses of an eye Report will be made public and OSHA may inspectNote: Failure to report can bring fines up to 12, 675. per instance.35 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.41 –Electronic SubmissionElectronic Submission RequirementsSubmissionYearEstablishmentswith 250 or moreemployeesEstablishmentswith 20-249employeesSubmissionDeadline2017Form 300AForm 300AJuly 1, 20172018Forms 300, 300A &301Form 300AJuly 1, 20182019300AAnnual SummaryForm 300AMarch 2,2019Note: State plans must adopt identical rules. 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsOSHA Injury & Illness Metrics TCIR Total Case Incidence Rate:(N / EH) x 200,000 TCIRN Columns G-J on OSHA 300 Log DART Days Away From Work, Restricted WorkActivity, and/or Job Transfer:(N* / EH) x 200,000 DARTN* Columns H&I on OSHA 300 LogN The total number of recordable cases (injuries & illnesses)N* The total number of lost, restricted and job transfer daysEH The total number of exposure hours (hours worked)200,000 100 employees working 40 hours per week for 50weeks (OSHA standard for all industries) 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts1904.35 – Employee AccessAccess & Retention Requirements Employees, former employeesand/or their personal or Retain forms for 5 years followingthe year that they coverrepresentatives have the right to Only update the OSHA Form 300during that periodaccess the OSHA Form 300 Log. Updates on the OSHA Form 300A orauthorized employee The employer must provideOSHA Form 301 not requiredaccess to the entire Form 300and may not delete employeenames except for privacyconcern cases.Note: According to OSHA the recordkeeping rule supersedes HIPPA regulations
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsEmployee Privacy Protection1904.29 (b) (6)Privacy concern cases are: An injury or illness to an intimate body part orreproductive system An injury or illness resulting from sexualassault, Mental illness HIV infection, hepatitis, tuberculosis Needle stick and sharps injuries that arecontaminated with another person’s blood orother potentially infectious material40Note: Employees can voluntarily request to keep name off for otherillness cases
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsCommon Errors in OSHA Recordkeeping Checking off more than one type of classification Incorrectly identifying the type of injury or illness Not providing enough detail about the location ofthe injury or illness Failure to identify the precise body part whenthere is more than one part involved Failure to sign the 300A Annual Summary and/orthe incorrect signature The accuracy of the lost & restricted days 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsCurrent Citations & PenaltiesVIOLATION TYPEPREVIOUSPENALTYOTHER THAN SERIOUSSERIOUSPOSTING REQUIREMENTSMandatory penalty forserious violations whichmay be up to 7,000. 12,500. per violationFAILURE TO ABATE 7,000. per day beyondthe abatement date 12,500. per day beyondthe abatement dateWILLFUL & REPEAT 70,000. per violation 125,000. per violationBipartisan Budget Act of 2015 – Effective Aug 2016 1.908-303.8359 FLEMINGTON, NJCURRENT PENALTY
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety Experts“Bulletproofing” Your Records Training employees and encouraging Employee Involvement Ensuring Employee Privacy Protection Completing, Certifying and Posting the Annual Summary Timely submission of the OSHA Form 300A (Annual Summary) Establishing a System for Retention and Updating Completing OSHA/BLS Surveys Conducting & Documenting an Annual Audit 1.908-303.8359 FLEMINGTON, NJ
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsQuestions?
THANK YOU!Jack Fearing, CPEAManaging PartnerFearing International Group LLC 1.908.303.8359 / ional.com
FEARING INTERNATIONAL GROUP LLCOccupational & Aviation Safety ExpertsAbout the SpeakerJack a Certified Professional Environmental Auditor (CPEA)and the Managing Partner for Fearing International GroupLLC, a Veteran-owned Small Business (VOSB) globaloccupational and aviation safety consulting firm.He has more than 30 years of experience in occupational safety andhealth management and DOD aviation safety and is a professionalmember of the New Jersey chapter of the American Society of SafetyProfessionals (ASSP). He was the CoPS Safety Professional of the Year(SPY) in 2008.He has extensive hands-on experience in developing OSHA complianceprograms, employee and management training and coordinating withstate and Federal regulatory agencies in both union and non-unionenvironments. He is an OSHA-Authorized 10/30 instructor (501-GeneralIndustry). Jack has a BS from the University of Massachusetts and anM.Ed. from Boston University in Environmental Science. He is a retiredUS Army Lt Colonel and served as a utility helicopter pilot and AviationSafety Officer in a Combat Aviation Brigade.4 1.908-303.8359 FLEMINGTON, NJ
Occupational & Aviation Safety Experts 8 1.908-303.8359 FLEMINGTON, NJ 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 Recordkeeping Forms 1904.29 -Forms
30-Hour OSHA Training – General Industry Course Topics Introduction to OSHA o Importance of OSHA o Worker Rights Under OSHA o Employer Responsibilities o OSHA Standards o OSHA Inspections o Where to Go for Help OSHA Inspection Procedures o Posting of Notice & Inspec
Nov 01, 2019 · OSHA 1-hour Lesson Directorate of Training and Education OSHA Training Institute Lesson Overview Purpose: To provide workers with introductory information about OSHA Topics: 1. Why is OSHA important to you? 2. What rights do you have under OSHA? 3. What responsibilities does your employer have under OSHA? 4. What do the OSHA standards say? 5.
Standards for General Industry OSHA 501: Trainer Course in OSHA Standards for General Industry OR OSHA 503: Update for General Industry Outreach Trainers OSHA 2015: Hazardous Materials OSHA 2045: Machinery and Machine Guarding Standards OSHA 2264: Permit-Required Confined Space entry OSHA 3095: Electrical Standards
OSHA Directorate of Training and Education 04.2010 OSHA Training Institute Introduction to OSHA STUDENT HANDOUT PACKET #1. Weekly Fatality/Catastrophe Report #2. OSHA Poster #3. MSDS Example #4. Your Rights as a Whistleblower Fact Sheet #5. Refusing to Work Because Conditions are Dangerous #6. OSHA 300 Log example #7. Employers Must Provide and .
23081 inspection requirements 23078 crane inspection checklist 1 23079 crane inspeciton checklist 2 23080 wirerope / hook inspection osha 1910.180 reference 23269 osha 1910.180, pg. 1 23270 osha 1910.180, pg. 2 23271 osha 1910.180, pg. 3 23272 osha 1910.180, pg. 4 23273 osha 1910.180, pg. 5 23274 osha 1910.180, pg. 6 23275 osha 1910.180, pg. 7
OSHA RECORDKEEPING HANDBOOK iii. iv OSHA RECORDKEEPING HANDBOOK Section 1904.12 Recording criteria for cases involving work-related musculoskeletal disorders 103 REGULATION 103 PREAMBLE DISCUSSION 103 Sections 1904.13 – 1904.28 (Reserved) 107 Section 190
OSHA WORKPLACE INJURY AND ILLNESS RECORDKEEPING: 2 Yor estions answered OSHA's requirements for keeping and maintaining workplace injury and illness records are found in Part 1904. Although the rules are written in plain language and seem easy to follow, recordkeeping can be challenging because it involves many judgment calls.
It is not strictly a storage tank and it is not a pressure vessel. API does not have a standard relating to venting capacities for low-pressure process vessels. It is recommended that engineering calculations be performed based on process and atmospheric conditions in order to determine the proper sizing of relief devices for these type vessels. However, it has been noted that may people do .
