“As in anything, when you break a complex process down into simple steps, you save yourself from confusion and needless worry,” Mangan assured attendees while making his presentation at the American Industrial Hygiene Conference and Exposition (AIHce) in Philadelphia.
Mangan explained that the following steps should be taken to ensure that a safety manager's recordkeeping is done as smoothly and efficiently as possible.
- Determine if your establishment is required to maintain records under 29 CFR 1904 – Recording and Reporting Occupational Illnesses and Injuries. If your company has 10 or fewer employees, you aren't required to fill out the form unless the Bureau of Labor Statistics (BLS) or OSHA tells you to do so in writing.
- Determine if it was an employee that was involved: If you provide day-to-day supervision of workers, you must record injuries and illnesses. Workers not on the payroll but still be included would be temporary health employees. If a worker from a temporary employment agency comes to work on a company's premises, their injury and/or illness would be recordable if the company manages or supervises them.
- Determine if the injury or illness was work-related: If the event of exposure in the work environment caused or contributed to a recorded injury or illness, it would be a recordable as well as if it significantly aggravated a pre-existing condition. However, there are questionable issues that many safety managers have. For example, if a worker is back on the work site as a member of the general public and he or she gets hurt, is that considered a work-related event? Mangan explained that such a scenario would not be considered a work-related event.
- Determine if the injury or illness is a new case: An injury or illness is considered a new case if this is the worker's first on-the-job injury or if the worker recovered from a previous injury or illness but had signs or symptoms reappear due to a work-related event or exposure.
- Determine if the injury or illness involves death, days away from work, restricted work or motion, as well as medical treatment beyond first aid. Other criteria include loss of consciousness, needlestick/sharp injuries and hearing loss (recordable when the total reduction is 25 decibels or more from audiometric zero).
- Define case for 300 Log: Explain the incident on the form.
- Evaluate extent and outcome.
- Complete, display and retain records.
Don't Confuse 300 Log With Workers' Comp Form
Under the Occupational Safety and Health (OSH) Act, every employer is required to maintain for each of their establishments a log of recordable injuries and illnesses. Mangan warned, however, to not confuse the OSHA 300 Log with a worker's compensation claim form.
“Many times we think that OSHA recordable is similar to workers' comp,” Mangan said. “Actually the two have nothing to do with one another.”
He explained that there are three reasons why OSHA recordables exist:
- They help BLS draw statistics on how may people were killed, injured and have lost-workdays.
- They help employers have an idea of where injuries and illnesses are being created in the workplace.
- They help OSHA keep track of which companies are experiencing large numbers of injuries, illnesses and fatalities.