SPECIAL POINTS OF INTEREST

SAFETY BULLETIN / April - June 2006

Download a .pdf copy of this bulletin

• Work environment-establishment or other locations…present…as a condition of employment. (Basically, the injury has to be related to the current job).
• Therefore no recording if:
  - Self-inflicted
  - During commute (parking lot)
  - Present as “general public”

General Rule:

• REPORT MEDICAL TREATMENT
• DON’T REPORT FIRST AID  

What is First Aid?

• Using a nonprescription medication at a nonprescription strength.
• Administering tetanus immunizations.
• Cleaning, flushing, or soaking wounds on the surface of the skin.
• Using wound coverings such as bandages, gauze pads, etc.; or using butterfly bandages or Steri-Strips.
• Using Hot or Cold Therapy.
• Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc.
• Using temporary immobilization devices while transporting an accident victim. (e.g., splints, slings, neck collars, back boards, etc.)
• Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister.
• Using eye patches.
• Removing foreign bodies from the eye using only irrigation or a cotton swab.
• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means.
• Using finger guards.
• Using Massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes)
• Drinking fluids for relief of heat stress.

Real Life (hurt at work or play?)

• Work or Home…You decide.
• Preexisting condition …
• No medical treatment required BEFORE the workplace exposure…
• Restrictions that would not have happened except for work activities

Recording Injuries and Illnesses

You are not required to record injuries and illnesses if:

• At the time of the injury or illness, the employee was present in the work environment as a member of the general public.
• The injury or illness involves signs or symptoms that surface at work but result solely from a non-work related event or exposure that occurs outside of the work environment.
• The injury or illness results solely from the voluntary participation in a wellness program or in medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball.
• The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption.
• The injury or illness is solely the result of an employee doing personal tasks at the establishment outside of the employees assigned working hours.
• The injury or illness is solely the result of personal grooming, self medication for a non-work-related condition, or is intentionally self-inflicted.
• The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work.
• The illness is the common cold or flu.
• The illness is a mental illness. Mental illness will not be considered work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience stating that the employee has a mental illness that is work related.

Significant changes from 200 to 300:

• Changes regarding lost/restricted work.
       - Change in terminology.
            - Eliminates “lost workdays”.
            - Focuses on “days away” or “days restricted or transferred”.
       - Includes new regulations for counting days.
       - Rely on calendar days instead of workdays.
• Changes to employer requirements.
       - Employers must establish procedure for employees to report injuries and illnesses.
       - Employers must tell employees how to report.
       - Employers are prohibited from discriminating against employees who report.
         With change of ownership, seller must turn over OSHA records to buyer.
• Changes to employee rights.
       - Privacy rights (i.e.: 300A, summary sheet)
            - Prohibits employers from entering an individual employee’s name on Form 300 for certain types of injuries/illnesses
                 - Sexual assaults.
                 - HIV infections.
                 - Mental illness.
            - Provides employers the right not to describe the nature of sensitive injuries where the employee’s identity would be known.
            - Gives employee access to portions of Form 301 relevant to the employee they represent.
            - Requires employers to remove employees’ names before providing data to persons not provided access under the rule (i.e.: lawyer).
• Requires the annual summary to be posted for three months (Feb. 1 to April 30) instead of one.
• Requires certification of annual summary by a company executive.
• Changes reporting of fatalities and catastrophes to exclude some motor carrier and motor vehicle incidents.
• Allows all forms to be kept on computer equipment or at alternate location.
• Form 300A
       - Requires increased employer review of data and additional data on the average employment/hours worked at establishment.
       - Changes result in higher quality data, but more time and cost to employer.
• Changes to the definitions of medical treatment and first aid (will result in more cases being recorded).

Areas of Potential Cost Increases:

• Change to the criteria for recording needle stick and sharps injury (will result in more cases being recorded).
• Increased employee involvement.
• Employee privacy protections.

Bloodborne Pathogen Standard:
An employer can choose to keep a separate sharps injury log to satisfy the requirements of 29 CFR 1910.1030, in addition to recording injuries on the OSHA 300 Log of Work-Related Injuries and Illnesses.
 
Basically, you need 2 logs: