Recordkeeping & Reporting WAC 296-27

1. Recordkeeping & ReportingWAC 296-27 Occupational Injury and Illness Forms: OSHA 301, 300, & 300A Presented by: Darrell Keith 360-416-3039 Safety & Health Specialist Department of Labor & Industries

2. Objectives / Outcomes • Discuss why injury & illness records are important. • Differentiate between recordable and non-recordable cases. • Review OSHA Recordkeeping Forms 301, 300, and 300A. • Complete exercises to increase skill in using the forms.

3. Why keep injury-illness records? • Captures data on how people get hurt. • Helps identify problem areas. • Helps prevent future injury or illness. • More effective safety program. • Increase employee safety awareness.

4. Which employers are exempt? • Employers with 10 or fewer employees in entire company at all times during the prior calendar year, includes temporary employees. • Employers in certain low hazard private establishments: • Pages 28-29 of WAC 296-27 • Public employer exemption: • Public Elementary and Secondary Schools • Public Libraries WAC 296-27-00103 & WAC 296-27-00105

5. Not Exempt in Washington • Employers who had 11 or more employees at any time the prior calendar year. • Offices and clinics of: • Medical Doctors • Dentists • Osteopathic Physicians • Other Healthcare Practitioners • Medical and Dental Laboratories • Health and Allied Services, NEC • Any employer who receives an OSHA/BLS survey. WAC 296-27-00103 & WAC 296-27-00105

6. Employees • Covered • All employees on payroll • All employees you supervise on a day-to-day basis • Not Covered • Sole proprietors • Partners WAC 296-27-02103

7. OSHA 301 Injury and Illness Incident Report • Filled out within 7 days of incident • Details about an incident WAC 296-27-01119

8. OSHA 300 Log • Record Specific Details • Filled out within 7 days of incident • What happened • How it happened WAC 296-27-01119

9. Separate Log and Summary for Each Establishment • Expected to be in operation at least one year • One log for all short term establishments • Link each employee to an establishment • First where the injury occurred or • Where the employee normally works WAC 296-27-02101

10. General Recording Criteria • Record a work-related injury or illness if it results in: • Death • Days away from work • Restricted work or job transfer • Medical treatment beyond first aid • Loss of consciousness • Significant injury or illness diagnosed by a licensed healthcare professional WAC 296-27-01107

11. Restricted Work or Job Transfer • Restricted Work • From one or more routine job functions or • Not work the full work day • Decision by employer or licensed health care professional recommendation • Job Transfer • Temporary or permanent change of job • At least part of the day WAC 296-27-01107

12. Medical Treatment • Medical treatment is: “Management and care of a patient to combat disease or disorder” • Does not include: • Visits for observation or counseling • Diagnostic procedures • First aid WAC 296-27-01107

13. Loss of Consciousness “Record a work-related injury or illness if the worker becomes unconscious, regardless of the length of time the employee remains unconscious.” WAC 296-27-01107(2)(f)

14. Significant Diagnosed Injury or Illness • Diagnosed but doesn’t meet other recording criteria. • Examples: • Punctured ear drum • Fractured toe or rib • Silicosis • Chronic irreversible diseases WAC 296-27-01107(2)(g)

15. Is it a new case? • Yes • No previous recorded injury/illness of this type to the body part Or • New event or exposure causes same type of injury/illness • Employee completely recovered from previous condition • No • Signs and symptoms re-appear or continue in the absence of a workplace exposure • You may rely on advice of licensed health care professional. WAC 296-27-01105

16. Is it work related? • NO • Employee present as part of general public • Symptoms from non work-related event • Voluntary participation in: • Wellness program • Medical fitness • Recreational activity WAC 296-27-01103

17. Is it work related? • NO (continued) • Eating, drinking, preparing food for personal consumption • Personal tasks at the establishment outside of work hours • Personal: • Grooming • Self-medication (non-work-related) • Intentional self-inflicted injury WAC 296-27-01103

18. Is it work related? • NO (continued) • Motor vehicle accident on company lot during commute. • Common cold or flu • Mental illness WAC 296-27-01103

19. Is it work related? • In travel status • Checked into hotel or other temporary residence. • “Home away from home” time • Commute to job location • Detour for personal reasons • Work activities “in the interest of the employer” NO NO NO YES WAC 296-27-01103

20. Is it work related? • Working at home: • Yes “… while performing work for pay or compensation in the home and the injury or illness is directly related to the performance of work rather than to the general home environment or setting.” • No • Due to general home environment or setting WAC 296-27-01103

21. “Privacy Case” • To protect injured employee’s privacy when forms are released: • Intimate body part or reproductive system • Sexual assault • Mental illness • HIV infection, hepatitis or tuberculosis • Needle stick/sharps injuries • Illness where employee voluntarily requests name not be used WAC 296-27-01119(2)(g)

22. Specific Recording Criteria • Needlestick and Sharps Injuries • Medical Removal Under a WISHA Standard • Occupational Hearing Loss • Tuberculosis

23. Needlestick and Sharps • Sharp objects • Contaminated with blood or • Other potentially infectious material • Enter the case as an injury • “Privacy Case” log entry • Update the log if necessary WAC 296-27-01109

24. Medical Removal • For WISHA standards such as • Lead  Formaldehyde • Cadmium  Benzene • Methylene Chloride • Record as “poisoning” if chemical exposure • Do not record voluntary removal before criteria are met WAC 296-27-01111

25. Occupational Hearing Loss • Record threshold shift if: • 10 dbA change from baseline and • 25 dbA overall hearing loss • One or both ears • 2000 hertz • 3000 hertz • 4000 hertz • Age adjustment tables located in WAC 296-27 WAC 296-27-01113

26. Tuberculosis • Recordable as “respiratory condition” if: • Occupationally exposed to anyone with known case of active TB And • Subsequently develops infection • Positive skin test or • Diagnosis by licensed health care professional • Line out or erase if later found not work related WAC 296-27-01115

27. Work-Related Musculoskeletal Disorders • Recordable cases as “injury” or “all other illnesses” • Follow same criteria as for other disorders • Work related • New case • General recording criteria

28. OSHA 300A Summary • Totals for the year • Certified by company executive • Posted Feb. 1 to Apr. 30 following year WAC 296-27-01119

29. Average Number of Employees Pay Period#of employees • 10 • 0 • 15 • 30 • 40 •  • 20 • 15 • +10 830 • Number of employees paid = 830 • Number of pay periods = 26 • 830 / 26 = 31.92 • 31.92 rounds to = 32 • Annual average number of employees = 32

30. Total Hours Worked 20 Number of full time employees X 2000Number of hours per full time employee 40000 Number of full time hours + 2200 Overtime, part time, temporary and seasonal hours 42,200 Total hours (rounded)

31. Retention & Updating of OSHA Forms • OSHA 301, 300, & 300A forms are to be saved for 5 years following the end of the calendar year that the records cover. • You must update your OSHA 300 Logs during that 5-year retention period. • You are NOT required to update the OSHA 301 or OSHA 300A. WAC 296-27-02107

32. Calculation DART = Total = 44 88040 1 5 2 4 X 5+2 =7 88040 15.9 5+2+4 =11 88040 25.0

33. More Information • DOSH • Recordkeeping Coordinator • Teri Neely leer235@lni.wa.gov 360-902-5446 • OSHA • OSHA Website • http://www.osha-slc.gov/recordkeeping