Cal/OSHA Recordkeeping Requirements - ACHD

Cal/OSHARecordkeepingRequirementsPresented by:Meg McCormickLoss Prevention SpecialistALPHA Fund

ObjectivesO Explain what constitutes a recordable injuryand/or illnessO Discuss how to fill out Cal/OSHA 300 LogO Explain when you must post the Cal/OSHA300A FormO Explain how long you must retain therequired records

California RecordkeepingO Initiated on September 14, 2001 by theDivision of Labor Statistics and ResearchO Provisions are in the CA Code ofRegulations, Title 8, Sections 1430014300.48

Purpose of 14300O Requires recording of work-related fatalities,certain injuries and illnesses

Recording vs ReportingRecordingO Partial exemptions (sections 14300.1 & 14300.2),based on various SIC codes or size of company (i.e.,do not have to record work-related fatalities,injuries, and illness on the Cal/OSHA Form 300)ReportingO No exemptions, all employers must report:O Immediately any serious occupational injury, illness ordeath to the Division of Occupational Safety and Health(DOSH), as required by Title 8, Section 342; andO Occupational injury, illness to the Division of LaborStatistics and Research (DLSR).

Recording Criteria14300.4-14300.29

Recording CriteriaOOOOOOOOOO14300.4 - Recording Criteria14300.5 - Work-relatedness14300.6 - New case14300.7 - General recording criteria14300.8 - Recording Criteria for Needlesticks and SharpsInjuries14300.9 - Recording Criteria for Medical Removal UnderCal/OSHA Standards14300.10 - Recording Criteria for Cases Involving OccupationalHearing Loss14300.11- Recording Criteria for Work-related TuberculosisCases14300.12 - Recording Criteria for Cases Involving Work-RelatedMusculoskeletal Disorders14300.29 - Forms

Recording CriteriaO Employers must record each fatality, injury,or illness that is:O Work-related,O A new case, ANDO Meets one or more of the general or specificrecording criteria

Determination of WorkRelatednessO A case is considered work-related if an eventor exposure in the work environment:O Either caused or contributed to the resultinginjury or illness, orO Significantly aggravated a pre-existing injuryor illness

What is considered “workenvironment”?O Physical location of workO Equipment or materials used by theemployee during the course of their work

Work-Relatedness ExceptionsO The injury or illness was caused by: Participation in a wellness program Personal grooming or self medication for non-work-related condition An intentionally self-inflicted act Motor vehicle accident in parking lot oraccess road during commute Common cold or flu

Exceptions continued Symptoms surface at work that are solelydue to non-work-related event or exposure Employee was present in the workenvironment as a member of the generalpublic Employee has a mental illness

Traveling and WorkRelatednessO An injury or illness that occurs while anemployee is on travel status IS work-relatedif it occurred while the employee wasengaged in work activities in the interest ofthe employer

How to RecordInjuries and Illnesses

General Recording CriteriaO Significant injury orO Restricted workillness diagnosed bya physician or LHCPO Loss ofconsciousnessO Medical treatmentbeyond first aidO Transfer to anotherjobO Days away from workO Death

FatalitiesO Mark the column for death

Days AwayO Days Away: Enter # of calendar days in the away from workcolumn Exclude the day of injury or illness Cap the total at 180 calendar days Count the # of calendar days the employee wasunable to work regardless of whether or not theemployee was scheduled to work or not

Restricted WorkO Occurs when the employee is kept fromperforming: One or more “routine functions” of the job Working a full dayO Count just like days away from workO Do not count if it is limited to only the day ofthe injury

Job TransferO Means the injured or ill employee isassigned to a job other than their regular jobfor at least a part of any work dayO Stop counting if a permanent modification ismade to a job or the employee ispermanently assigned to the modified job

Medical Treatment BeyondFirst AidO Means the management and care of apatient to combat disease or disorderO Does NOT include:O Visits to LHCP solely for observation orcounselingO Diagnostic proceduresO First aid

First AidO Nonprescription meds at nonprescriptionOOOOOstrengthTetanus immunizationsCleaning, flushing or soaking wounds on thesurface of the skinWound coverings such as bandages, gauze,etc.Hot or cold therapyNon-rigid means of support

First aid continuedO Temporary immobilization devices (e.g. splints,OOOOslings, neck collars, etc.)Drilling of a fingernail or toenail to relievepressure, or draining fluid from a blisterEye patchesRemoving foreign bodies from the eye usingirrigation or cotton swabRemoving splinters or foreign materials fromother areas by irrigation, tweezers, cottonswabs, etc.

More first aidO Using finger guardsO MassagesO Drinking fluids for relief of heat stressO This is a complete list of ALL treatmentsconsidered first aid for purposes of Article 2.

Loss of ConsciousnessO Must be recorded regardless of the length oftime the employee remains unconscious

Significant Diagnosed Injuryor IllnessO Includes (but is not limited to) cancer,chronic irreversible diseases (ex: asbestosis,silicosis), fractured or cracked bones,punctured eardrums

Recording Needlesticks andSharpsO Record Exposures to blood or OPIM as: Injuries if sticks or cuts from sharps areinvolved Illnesses if a splash or other exposure resultin a diagnosis of a bloodborne illness (ex: HIV,Hepatitis C) Medical treatment beyond first aid (ex: HIVprophylaxis, Hep B Immune globulin, Hep BVaccination)

Recording Needlesticks andSharpsO If cuts, lacerations, punctures or scratches arework-related and do not involve contaminationwith another persons blood or OPIM thenrecord only if the incident involved: DeathDays away from workRestricted workTransfer to another jobMedical treatment beyond first aidLoss of consciousnessSignificant injury or illness diagnosed by aphysician or other licensed health care professional

Privacy Concern CasesO Injury or illness to an intimate body part or theOOOOOreproductive systemInjury or illness resulting from a sexual assaultMental illnessesHIV infection, hepatitis, or tuberculosisNeedlestick injuries and cuts from sharps thatare contaminated with another persons blood orOPIMIf the employee independently and voluntarilyrequests that his or her name not be entered onthe log

FormsCal/OSHA Forms 300 & 301

FormsO Complete Cal/OSHA Forms 300 &301 or equivalent form within 7calendar days of receiving informationof a recordable case Cal/OSHA Form 300 - Log of Work-Related Injuries and Illnesses Cal/OSHA Form 301 - Injury and IllnessIncident Report

Annual SummaryO Requirements Review the Cal/OSHA Form 300 Create an annual summary of injuries andillnesses using Cal/OSHA Form 300A Certify the annual summary Post the annual summary

Reviewing the AnnualSummaryO You must review the entries as extensivelyas necessary to make sure they arecomplete and correct

Creating the SummaryTotal the columns on the Cal/OSHA Form3002. Enter the calendar year covered, thecompany’s name, establishment name,establishment address, annual averagenumber of employees covered, AND totalhours worked by all covered employees1.

Certifying the SummaryO A company executive must certify that he orshe has examined the Cal/OSHA Form 300O Who is considered a company executive? An owner of the company Officer of the corporation Highest ranking company official Immediate supervisor of the highest rankingofficial

Posting the SummaryO Post in a conspicuous place or places wherenotices to employees are customarily postedO Must be posted no later than February 1through April 30

Covered EmployeesO All employees on your payroll, including:O LaborO ExecutiveO HourlyO SalaryO Part-timeO SeasonalO Migrant worker

What about traveling nurses?O If the contractor's employee is under theday-to-day supervision of the contractor, thecontractor is responsible for recording theinjury or illness. If you supervise thecontractor employee's work on a day-to-daybasis, you must record the injury or illness.O In a nutshell, they would probably fall underyour organizations supervision

Retention and UpdatingO Retain forms for 5 years after the year the formcoversO Update Cal/OSHA Form 300 during retentionperiod if: Newly discovered recordable cases arise Changes occur in the classifications Changes occur in the description or outcomeO You do not need to update the Cal/OSHA Form300A or Cal/OSHA 301 during the retentionperiod

Basic Requirements forEmployee InvolvementO Inform each employee of how he or she is toreport an injury or illness to youO Establish a procedure to reportO Inform employees on how to follow theprocedureO Provide limited access to your injury andillness records for your employees and theirrepresentatives

OverviewO Post your summary from February 1-April 30O Retain records for 5 yearsO Train employees on how to report all injuriesand illnesses

Questions?

ResourcesO bjectIndex/SubjectIndex.htmO http://www.dir.ca.gov/dosh/dosh publications/reckeepoverview.pdf

O 14300.9 - Recording Criteria for Medical Removal Under Cal/OSHA Standards O 14300.10 - Recording Criteria for Cases Involving Occupational Hearing Loss O 14300.11- Recording Criteria for Work-related Tuberculosis Cases O 14300.12 - Recording Criteria for Cases Involving Work-Related Musculoskeletal Disorders O 14300.29 - Forms