Excerpt: Just when employers had routine down and understood the
difference between an illness and an injury and what to report and record on
the OSHA 200 logs, the rules changed. Indeed on
January 19th, 2001 the Occupational Safety and
Health Administration, OSHA, disseminated the changes of the new recordkeeping
requirements, forms, and definitions. The implementation date for compliance by
employers is
January 1st 2002.
Written information may be contained on the new requirements of OSHA’s website.
OSHA’s recordkeeping requirements have been implemented since 1971 and were
created to help employers identify workplace hazards and correct conditions
hazardous to employees by maintaining records and tracking injuries, illnesses,
and their causes. The new rule has been created to simplify the record keeping system
and the use of technology for employees. The revisions provide better
information about occupational illnesses and injuries and their causes.
Emphasis is also being placed on better production of an employee’s privacy.
Let’s begin by looking at the three new forms to be used in
the new recordkeeping requirements. Previously the 200 log was used to track
work place injuries and illness. The new form is called the OSHA Form 300. The
second new form is the OSHA Form 301 referred to as the injury and illness
incident report. This new form replaces the old OSHA Form 101, and will include
more data about how the injury or illnesses occurred. Read the self-explanatory
directions to complete the OSHA Form 301. Examples are provided to guide the
record keeping in properly completing the details of the information about how
the illness or injury occurred. Additionally, a requirement for the employer to
be aware of is the posting of the final new form OSHA Form 300A, formerly known
as summary of injuries and illness, or the Form 102. Previously Form 102 was posted
for 1 month. The OSHA Form 300A must be signed and certified by a company
executive and posted from February 1 to April 30 for three months. Highlights
of the additional changes include:
1) What
set of criteria to be used for determining whether an injury or illness is to
be recorded
2) Definitions
of key terms such as First Aid, Medical Treatment, and Restrict Work have been
changed. Under the new rule the employer will be required to report cases when
an injury or ill employee’s normal duties performed regularly at least once a
week are restricted
3) Among
the eliminated key terms and definitions is Lost Work Days replaced by new
terms such as Days Away, or Days Restricted. Days Away or restricted duty would
be based on calendar days instead of scheduled work days for the affected
employee. Employers are required to establish a procedure for employees to
record injuries and illnesses and to inform employees of the procedure to be
followed. In addition a criteria for deciding when mental illnesses are considered
work related has been added. There is also special recording criteria for
medical removal under OSHA standards for cases involving the work related
transmission of tuberculosis.
The new rules and requirements may
undoubtedly cause confusion for many employees. The time to start investigating
record keeping requirements and obligations is now. This program will provide
information and explanation for the new OSHA Form 300 and other new forms.
Let’s begin by viewing the first
of the three forms titled OSHA Form 300, log of work related injuries and
illnesses. Now let’s work through each of the line items listed. Let’s begin by
looking at the top left hand side of the form that identifies the OSHA Form
300. Please read the boxed section explanation beginning with the bold word.
Attention: This form contains information relating to employee health and must
be used in a manner that protects the confidentiality of employees to the
extent possible while the information is being used for occupational safety and
health purposes. Please complete the information on the right hand corner. This
is the line for the year the form is being completed, and when the injuries or
illnesses occurred. Beneath the top heading is written information for the criteria
and instructions to complete the record keeping required, and guidance to the additional
forms to be used for recording and reporting to OSHA. On the right side
complete the establishment name.
