Recordkeeping

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Recordkeeping
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Safety Recordkeeping

• OSHA mandates some recordkeeping
• Project owners often require some forms of safety
  recordkeeping
  
• Employers are wise to implement other forms of
  recordkeeping

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Why Does OSHA Mandate Recordkeeping?

• The information is generally related to injury
  frequency and illness incidence
  
• Trends can be observed over time
• OSHA recordkeeping requirements is that this
  information can be useful to OSHA as it seeks
  direction in its mission
  
• Tells industry how it is doing

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OSHA Recording Requirements(for Firms with 11 or
more employees)

• OSHA Log No. 300 (Each injured worker is named,
  the extent of the injury, or the nature of the
  illness). Recordable only.
  
• OSHA Supplementary Record No. 301 (formerly 101)

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In 2004 Additional Reporting

• Beginning January 2004
• Employers will be required to report work-related
  hearing loss
  
• Must record 10-decibel shifts from the employees
  baseline hearing test (resulting in an overall
  hearing loss of 25 decibels)
  
• Musculoskeletal disorders (MSDs) reporting
  requirements are postponed

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What is Recordable?

• Requires treatment by a physician
• Worker becomes unconscious
• Worker ability to work is restricted
• Re-injury requiring treatment
• Injuries occurring off-site needing treatment
• Injury must be work-related

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What is not Recordable?

• First aid treatment only
• Observation by a physician but not treated
• Hospitalized but not treated

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Are the following Recordable?

• Treatment limited to cleaning, soaking, applying
  antiseptic and bandaging a wound?
  
• No

• Medical glue was applied to close multiple
  lacerations?
  

Yes
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Are the following Recordable?

• Applying non-prescription ointments on follow-up
  visits to prevent drying and cracking of skin?
  
• No

• Butterfly bandages were applied to multiple
  lacerations?
  

No
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Are the following Recordable?

• Removal of embedded foreign material from the
  eye?
  
• Yes

• Second or subsequent hot and cold soaks and use
  of whirlpool treatments?
  

No
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Are the following Recordable?

• Drilling a fingernail to drain the fluid and
  relieve the pressure?
  
• No

• One-time administration of oxygen for several
  minutes?
  

Yes
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Are the following Recordable?

• Following a chest X-ray, an employee was
  diagnosed with silicosis?
  
• Yes

• One-time administration of prescription
  medication to alleviate minor discomfort?
  

Yes
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Are the following Recordable?

• Additional cleaning and application of antiseptic
  because the bandage became soiled?
  
• No

• Medical removal as mandated by OSHA standard due
  to cadmium poisoning?
  

Yes
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Are the following Recordable?

• Employee injures back at work and has one
  chiropractic adjustment?
  
• Yes

• Loss of consciousness?

Yes
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Are the following Recordable?

• Following an X-ray of a rib for a fracture, X-ray
  indicates the rib is not broken?
  
• No

• Reaction to flu shot administered on-site on a
  voluntary basis?
  

No
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Are the following Recordable?

• The injury is the result of choking on a sandwich
  from the employees brown bag lunch?
  
• No

• Adding eye drops to eye in order to dilate pupils
  for diagnostic purposes?
  

No
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Are the following Recordable?

• Needlestick from sharp object contaminated with
  potentially infectious material?
  
• Yes

• Employee with work-related elbow pain and is
  given non-prescription pain medication at
  prescription strength?
  

Yes
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OSHA Supplementary Record No. 301

• Provides details of a single injury
• Similar to information requested by workers
  compensation carriers

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Maintain Good Records

• Log 300 and No. 301 (formerly 101) to be on site
  at all times
  
• Central dispatch office can be used for records
  if workers begin workday there
  
• Keep records for 5 years

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The Annual Summary ReportForm 300A

• Posted at the place of employment from February 1
  to May 1 (3 months)
  
• Summary to include type of injury and the number
  of lost workdays
  
• If no injuries, post with zeroes on the total
  lines

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Other Recordkeeping

• First Aid and Medical Assistance
• First Aid Supplies and Medical Service Available
• Employees Informed of Medical Results
• Emergency Procedures and Training, Where
  Necessary
  
• Surveillance Records Asbestos, Lead

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Accident Investigations

• Detailed analysis of what happened
• Witness accounts, etc.
• Reasonable options to avoid further occurrence
• Communication of findings

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In How Many Recordable Injuries is Top Management
Involved in the Investigation?
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Documenting Near Misses

• To Conduct Trend Analysis
• Be Aware of Problems before an Injury Occurs

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Number of Near Misses Documented per Project
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Worker Observations

• Document unsafe behavior
• Conduct trend analysis
• Worker involvement in the process
• No name, no blame

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Number of Observations Recorded
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Identification of Safety Violations

• Reprimands
• Terminations

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Are Sanctions in Place for Subcontractors Who Do
Not Comply With Safety Requirements?
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