OSHA 2002 Recordkeeping Simplified

497 Pages·2002·23.99 MB·English

OSHA 2002
Recordkeeping
Simplified
OSHA 2002
Recordkeeping
Simplified
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OSHA 2002
Recordkeeping
Simplified
James E. Roughton
r~UTTE RWO RTH
E ! N E M A N N
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Dedication
To my wife, my friend, my lifelong partner, who has always been
patient with me in my endeavors to enhance my safety profession.
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Contents
Preface ................................................ xi
Acknowledgments ..................................... xix
Acronyms ............................................ xxi
About the Author ..................................... xxiii
Introduction ............................................ 1
Highlights and Major Changes to OSHA's Recordkeeping Rule, 1
How Can I Tell If I Am Exempt?, 4
Low-Hazard Industry Exemption, 4
What Is Important About Recordkeeping?, 8
An Overview of What Has Changed, 8
Overview of the New Forms, 9
Work-Related Status, 9
Recording Criteria, 10
Day Counts, 11
Annual Summary, 11
Employee Involvement (Participation), 11
Protecting Privacy, 12
Reporting Information to the Government, 12
Provisions Delayed, 12
How Can I Get More Information on Recordkeeping?, 13
State Programs, 13
Part I UNDERSTANDING THE RULE ........................ 15
1. Overview of the Final Regulation ........................ 17
Changes to the New Rule, 17
Transition from the Old Rule to the New Rule, 18
Changes in the Recording Criteria, 19
Overview of the Final Regulation, 24
New OSHA Instructions, 25
Recording and Reporting Requirements, 25
VIoIo
viii Contents
Enforcement Date, 26
Summary of the New Recordkeeping Rule, 26
Citations and Penalties, 38
Recording Criteria for Cases Involving Medical Removal, 39
Privacy Concern Cases--Employee Privacy, 40
Physician or Other Licensed Health Care Provider's Opinion, 41
Other Changes, 42
2. Occupational Injury and Illness Recording and Reporting
Requirements, Part 1904 ................................. 48
Purpose-- Subpart A, 51
Definitions, Section 1904.46, Subpart G, 51
Scope--Subpart B, 58
Partial Exemption for Employers with 10 or Fewer Employees,
Section 1904.1, 59
Partial Exemption for Establishments in Certain Industries,
Section 1904.2, 60
Keeping Records for More Than One Agency, Section 1904.3, 63
Recordkeeping Forms and Recording Criteria--Subpart C, 63
Recording Criteria, Section 1904.4, 64
Determination of Work-Relatedness, Section 1904.5, 69
Determination of New Cases, Section 1904.6, 85
General Recording Criteria, Section 1904.7, 90
Additional Criteria, Sections 1904.8 through 1904.12, 111
Reserved, Sections 1904.13 through 1904.28, 119
OSHA 300 Forms, Section 1904.29, 119
Other OSHA Injury and Illness Recordkeeping Requirements--
Subpart D, 124
Multiple Business Establishments, Section 1904.30, 124
Covered Employees, Section 1904.31,125
Annual Summary, Section 1904.32, 126
Retention and Updating, Section 1904.33,130
Change in Business Ownership, Section 1904.34,131
Employee Involvement (Participation), Section 1904.35,131
Prohibition Against Discrimination, Section 1904.36, 135
Variances from the Recordkeeping Rule, Section 1904.38, 136
Providing Records to Government Representatives,
Section 1904.40, 138
Transition from the Former Rule--Subpart F, 139
Summary and Posting of the 2001 Data, Section 1904.43,139
Retention and Updating of Old Forms, Section 1904.44, 139
Amended Part 1952, 140
Reporting Fatality, Injury, and Illness Information to the
Government - Subpart E, 141
Reporting Fatalities and Multiple Hospitalization Incidents to
OSHA, Section 1904.39, 141
Contents ix
Annual OSHA Injury and Illness Survey of Employers of 10
or More Employees, Section 1904.41,143
Requests from the Bureau of Labor Statistics for Data, Section
1904.42, 146
OMB Control Number Under the Paperwork Reduction Act,
Section 1904.45,146
Part II PROGRAMS THAT SUPPORT THE RECORDKEEPING
RULE ................................................ 149
3. Conducting Effective Incident Investigations ............. 151
Root Causes Defined, 151
Benefits of Root Cause Analysis, 152
Incident Prevention, 153
What Causes Incidents?, 154
Elements of the Safety System, 154
What Should Be Investigated?, 155
Who Should Investigate an Incident?, 158
Analysis of Patterns, 159
Interviewing Injured Employees, 161
Interviewing Witnesses, 161
Re-creating the Incident, 164
Determining Cause, 164
Corrective Action Plans, 165
Problem-Solving Techniques, 166
Investigation Report, 167
4. The Benefits of Job Hazard Analysis ................... 170
Why Do a JHA?, 170
Assigning Responsibility, 172
Conducting a JHA, 172
Breaking Down the Job, 173
Developing a Priority List of Tasks, 175
Using Employee Participation to Develop Task-Specific JHAs, 179
Reviewing the JHA Until Employees Understand the Hazards
of the Job, 180
Developing an Action Plan to Identify Incidents, 180
5. Developing and Administering a Medical Surveillance
Program .............................................. 185
Why Do You Need a Medical Surveillance Program?, 185
Who Should Manage the Medical Provider?, 186
What Services Do You Need from a Medical Provider?, 187
The Range of Medical Provider Functions, 188
Early Recognition and Treatment, 188