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OSHA Recordkeeping in the Healthcare Setting

Objectives1. Outline OSHA’s Recordkeeping Requirements for Hospitaland Healthcare Organizations2. Explain updated COVID-19 directives that impact theOSHA Recordkeeping Process3. Describe how to use OSHA Recordkeeping and other workaccident data in your Safety and Health ManagementProgram1

Brief History of the BLS & OSHA2

1940’s BLS (Bureau of Labor Statistics) begins collectingwork injury dataLimited in scope and voluntary for employers3

December 1970 – Occupational Safety and HealthAct (OSH Act) is signed into law by PresidentRichard NixonApril 28, 1971 OSHA is formed4

Purpose of OSHA“ .to assure safe and healthful working conditionsfor working men and women .”https://www.osha.gov/laws-regs/oshact/section 15

Purpose of OSHA Recordkeeping“The OSHA Recordkeeping system is intended to collect,compile and analyze uniform and consistent nationwidedata on occupational injuries and sha-3006

OSHA Injury & Illness RecordkeepingRule 29 CFR Part 19047

Sections of OSHA’s Recordkeeping RuleStandard Number - 1904Subpart A - PurposeSubpart B - ScopeSubpart C - Forms and recording criteriaSubpart D - Other requirementsSubpart E - Reporting to the governmentSubpart F - TransitionSubpart G - Definitions8

29 CFR Part 1904 - Subpart APurpose (of the Rule)To require employers to record and report work-relatedfatalities, injuries, and illnesses9

29 CFR Part 1904 - Subpart B - Scope1904.1 – Small employer partial exemptions If 10 or fewer employees at all times during the lastcalendar year1904.2 – Partially exempt industries If establishment classified in specific industry group, donot need to keep OSHA injury and illness records(see OSHA’s appendix A to 1904 Subpart B for a complete list of partially exempt industry standardnumber/1904/1904.210

Partially Exempt Healthcare related IndustriesSome examples of partially exempt healthcare relatedindustries1. Offices of Physicians2. Offices of Dentists3. Offices of Other Health Practitioners4. Outpatient Care Centers5. Medical and Diagnostic Laboratories11

Covered Healthcare IndustriesThat Must Record Injuries and Illnesses1.2.3.4.General Medical & Surgical HospitalsPsychiatric and Substance Abuse HospitalsSpecialty (except Psychiatric and Abuse) HospitalsNursing Care Facilities (Skilled Nursing Facilities)12

29 CFR Part 1904 - Subpart CRECORDKEEPING FORMS & RECORDING CRITERIAMust record all new cases of work related fatalities,injuries, and illnesses that meet one or more of thecriteria contained in sections 1904.7 through 1904.11.13

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General Recording Criteria1904.7Injuries or Illness that involve one or more of the followingmust be recorded on the OSHA 300 Log DeathDays away from workRestricted Work or Job TransferMedical Treatment beyond first aidLoss of consciousnessOther significant injuries or illnesses15

Days Away Cases1904.7(b)(3)Record if the case involves one or more days away fromwork (excluding day of injury or illness)Check the box for days away cases and count the numberof calendar days16

Days Away Cases1904.7(b)(3) (continued) Cap day count at 180 days away and/or days restricted May stop day count if employee leaves company for areason unrelated to the injury or illness17

Restricted Work Cases1904.7(b)(4)Record if the case involves one or more days of restrictedwork or job transfer (excluding day of injury or illness)Check the box for restricted/transfer cases and count thenumber of days18

Restricted Work Cases1904.7(b)(4) (continued)Restricted work means the employees is: Unable to work the full workday he or she wouldotherwise have been scheduled to work; or Unable to perform one or more routine job functionsRoutine Job Functions: those activities the employeeregularly performs at least once per week19

Job Transfer1904.7(b)(4)Definition of Job transferAn injured or ill employee is assigned to a job other thanhis or her regular job for part of the dayA case is recordable if the injured or ill employee performshis or her routine job duties for part of a day and isassigned to another job for the rest of the day20

Medical Treatment1904.7(b)(5)(i)Definition of Medical Treatment“The management and care of a patient to combatdisease or disorder.”21

Medical Treatment1904.7(b)(5)(i)(A) & (B)Medical Treatment DOES NOT include: Visits to Medical Provider solely for observation orcounseling Diagnostic procedures22

What is “First Aid”1904.7(b)(5)(ii) 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 victims23

First Aid (continued)1904.7(b)(5) Drilling of fingernail or toenail, draining fluid from blister Eye patches Removing foreign bodies from eye using irrigation orcotton swab Removing splinters or foreign material from areas otherthan the eye by irrigation, tweezers, cotton swabs orother simple means Finger guards Massages Drinking fluids for relief of heat stress24

Classifying the Injury and Type of IllnessColumn (M) - OSHA 300 LogDefinition of “Injury”Any wound or damage to the body resulting from an event in the workenvironment. Cut, puncture, laceration, abrasion, fracture, bruise,amputation, insect bite, electrocution, or a thermal, chemical,electrical, or radiation burn. Sprain and strain injuries to muscles,joints, and connective tissues are classified as injuries when theyresult from a slip, trip, fall or other similar rkforms-winstr fillable.pdf25

Classifying the Injury and Type of IllnessColumn (M) - OSHA 300 LogIllness Type: Skin diseases or disorders are illnesses involving theworker’s skin that are caused by work exposure to chemicals,plants, or other -rkforms-winstr fillable.pdf26

Classifying the Injury and Type of IllnessColumn (M) - OSHA 300 LogIllness Type: Respiratory conditions are illnesses associated withbreathing hazardous biological agents, chemicals, dust, gases,vapors, or fumes at ms-winstr fillable.pdf27

Classifying the Injury and Type of IllnessColumn (M) - OSHA 300 LogIllness Type: Poisoning includes disorders evidenced by abnormalconcentrations of toxic substances in blood, other tissues, otherbodily fluids, or the breath that are caused by the ingestion orabsorption of toxic substances into the ms-winstr fillable.pdf28

Classifying the Injury and Type of IllnessColumn (M) - OSHA 300 LogIllness Type: Severity Type: Hearing Loss is noise-induced hearingloss as defined for recordkeeping purposes as a change in g/osha-rkforms-winstr fillable.pdf29

Classifying the Injury and Type of IllnessColumn (M) - OSHA 300 LogIllness Type: All other illnesses include heatstroke, sunstroke, heatexhaustion, heat stress and other effects of environmental heat;effects of ionizing radiation (isotopes, x-rays, radium); effects ofnonionizing radiation (welding flash, ultra-violet rays, lasers);anthrax; blood borne pathogenic diseases, such as AIDS, HIV,Hepatitis B or Hepatitis C; brucellosis; malignant or benign tumors;histoplasmosis; ing/osha-rkforms-winstr fillable.pdf30

Loss of Consciousness1904.7(b)(6)All work-related cases involving loss of consciousnessmust be recorded31

Significant Diagnosed Injury or Illness1904.7(b)(7)Always record the following work related conditions:(even if no treatment rendered) CancerChronic irreversible diseasePunctured eardrumFractured or cracked bone or tooth32

Recording Criteria for Needlesticksand sharps injuries - 1904.8All work-related “contaminated sharps” i.e. needlesticksand cuts from sharp objects that are contaminated withanother person’s blood or OPIM must be recorded onthe OSHA 300 LogOPIM Other Potentially Infectious Material33

Non-Sharps Recording Criteria - 1904.8(b)(4)Only record work-related splashes or “non-sharp” relatedexposures to blood or OPIM if it results in a diagnosisof a bloodborne disease or meets the generalrecording criteria34

Medical Removal1904.9 Work Exposures in which an employee is medicallyremoved under the medical surveillance requirements ofan OSHA standard, must be recorded on the OSHA 300Log.Examples: Lead, cadmium, methylene chloride,formaldehyde, benzene etc.35

Hearing Loss1904.10Must record all work-related hearing loss cases where: An employee’s hearing test (audiogram) demonstrates theyhave experienced a work-related Standard Threshold Shift(STS) in hearing in one or both ears, and the total hearinglevel is 25 decibels (dB) or more above audiometric zero(averaged at 2000, 3000, and 4000 Hz) in the same earsas the STS.See OSHA Standard Number 1904.10 for complete details36

Tuberculosis1904.11Work related exposures to someone with a known case ofactive TB that develops into a TB infection must berecorded on the OSHA Log.37

OSHA 300 Log & 301 Form1904.29(b)(3) Record case in log and complete OSHA 301 formwithin 7 calendar days of receiving information.38

OSHA Form 301Injury and Illness Incident Report39

OSHA 300 Log & 301 Form1904.29(b)(3) continued Forms that have all of the same information that is onthe OSHA 301 Form may be usedExample: work accident or incident reports40

OSHA 300 Log & 301 Form1904.29(b)(3) continued Computer records are permitted if they can be produced when needed41

OSHA Log - Privacy Concern Cases1904.29(b)(6) Do not enter the name of an employee on the OSHA 300Log for “privacy concern cases” Enter “privacy case” in the name column Keep a separate confidential list of the case numbersand employee names42

Privacy Case Determination1904.29(b)(7)Privacy concern cases are: Injuries or illnesses to an intimate body part orreproductive system Injury or illness from a sexual assault Mental illness43

Privacy Case Determination1904.29(b)(7) continuedPrivacy concern cases are: HIV infection, hepatitis, tuberculosis Needlestick or sharps injuries contaminated with anotherperson’s blood or OPIM Employee requests to keep their name off44

Sharps Injury Log29 CFR 1910.103045

Sharps Injury Log29 CFR 1910.1030 Must establish and maintain a sharps injury log recordingof percutaneous injuries from contaminated sharps Must be recorded in such manner as to protect theconfidentiality of the injured employee46

Sharps Injury Log29 CFR 1910.1030Minimum information that should be on the log(A) The type and brand of device involved in the incident,(B) The department or work area where the exposureincident occurred, and(C) An explanation of how the incident occurred.47

29 CFR Part 1904 - Subpart DOther OSHA Injury & Illness RecordkeepingRequirements 1904.30 – Multiple business establishments1904.31 – Covered employees1904.32 – Annual summary1904.33 – Retention and updating1904.34 – Change in business ownership1904.35 – Employee involvement1904.36 – Prohibition against discrimination1904.37 – State recordkeeping regulations1904.38 – Variances from the recordkeeping rule48

Multiple Business Establishments1904.30OSHA Recordkeeping for: Hospital Other Locations Hospital or Health System Employees working atmultiple locations49

Covered Employees1904.31The following employees are to be recorded on theOSHA 300 Log All employees on your payroll Temp Employees you supervise on a day-to-day basisi.e. Agency RN, CNA, etc. Contractor employees you supervise on a day-to-daybasis50

Annual Summary of Work-RelatedInjuries and Illnesses - OSHA 300A - 1904.3251

Annual Summary of Work-RelatedInjuries and Illnesses - OSHA 300A - 1904.32At the end of each calendar year you must prepare andpost form OSHA 300A.52

Annual Summary of Work-RelatedInjuries and Illnesses - OSHA 300A (continued) Review & Update OSHA 300 Log to verify that theentries are complete and accurate53

Annual Summary of Work-RelatedInjuries and Illnesses - OSHA 300A (continued) Create annual summary of injuries and illnesses usingthe OSHA 300A form and data from the OSHA 300 Log54