Did you know that the OSHA Illness and Injury Summary Log, 300A, is used for more than just recordkeeping at your site?  By documenting your company’s illness and injuries properly, you shape OSHA’s future initiatives!  Specifically, OSHA Summary 300A Forms are gathered by the OSHA Data Initiative (ODI) to help direct OSHA programs and measure its own performance.  

How does OSHA get this information?

OSHA gets these data from two sources:

• As part of an annual survey, the Bureau of Labor Statistics (BLS) sends injury and illness survey forms to randomly selected employers and uses the information to create the Nation’s occupational injury and illness statistics.
• The OSHA Data Initiative mails its annual survey (in June) that collects data on injuries and acute illnesses attributable to work-related activities in private-sector industries from approximately 80,000 establishments in selected high hazard industries. In 2010, OSHA also collected this information from approximately 20,000 establishments in the construction industry in addition to the non-construction establishments. The Agency uses these data to calculate establishment-specific injury/illness rates, and in combination with other data sources, to target enforcement and compliance assistance activities. Traditionally, OSHA collects data from the establishments that meet the following categories, but as we saw in 2010, OSHA can expand these criteria.
  • Non-construction industries with 40 or more employees are chosen randomly
  • Non-respondents in the previous collection year
  • Site with an inspection or consultation visit for performance measurement
  • DART rate (days away from work, restriction or transfer) of 7.0 or higher in previous data collection

Does the data really help OSHA?

Now that OSHA has the data from BLS and the ODI, the Agency uses the information to

• Calculate and establish specific injury and illness incidence rates
• Develop targeted intervention programs (i.e., inspections and enforcement action)
• Assist inspectors so that they can direct their efforts to the higher incidents hazards that are hurting workers.
• Measure the success of agency efforts to reduce the number of workplace injuries and illnesses in select high-hazard industries
• Provide the base data for the BLS Annual Survey of Occupational Injuries and Illnesses, the Nation’s primary source of occupational injury and illness data.

What is your role?

Be a savvy and educated reporter of your company’s illness and injury information. Understanding the OSHA 300 log reporting requirements will ensure an accurate portrayal of worker health and safety as well as maintaining OSHA compliance. Can you answer the following questions?

• How do I complete the OSHA 300 Log and Form 301?
• Am I required to post an OSHA Form 300A ? How do I know if I am exempt? 
• What is classified as a work-related illness or injury? 
• How do I fill the forms in correctly without over-reporting?
• Do I have to fill in the form if I have no recordable injuries or illnesses in the previous year? What are the rules for posting?
• Once the form is filled in and submitted, if requested by BLS or OSHA, are there other legal requirements I should know?

Not convinced that recordkeeping is important?

Besides providing a visible record of worker safety benchmarks and improvements (or worse, tragedies and reversals), establishments that are requested to but fail to submit a completed data collection form may be subject to OSHA enforcement actions, including the issuance of a citation and assessment of penalties!  So, take the time understand OSHA’s reporting requirements and implement them correctly – it affects your company and the nation’s workers.

If you need assistance with OSHA recordkeeping, Emilcott offers a variety of ways to help your business stay in compliance from a webinar-based course that outlines the rules and regulations to the development of complete health and safety plans. Or, if you have an OSHA recordkeeping question, just ask us!

An effort to raise awareness – You never know when an emergency is going to happen. You must be and stay prepared for the unexpected at home, in school, at the workplace and in your community. Some emergencies which may happen: A Biological Threat , Blackouts, Earthquakes, Explosions, Fires, Floods, Hurricanes, Influenza Pandemic, Tornadoes, Wildfires, Winter Storms
Follow these simple steps for confidence during a disaster or crisis which may occur…

1. Create a kit of emergency supplies… (placing everything in a backpack is a great idea in case you have to evacuate quickly)

Items to include in your kit should be:

Copies of your important documents placed into a waterproof container
Birth certificates
Photo ids
Insurance cards
Copies of credit cards and ATM cards
Extra set of keys to your house and car
Cash or Traveler’s checks (stored in a waterproof container)
A week’s supply of medications and a list of the medications you take
Dosages, doctor’s names, doctor’s phone numbers
Flashlight and extra batteries
First aid kit
Battery operated radio and extra batteries
Bottled water and non-perishable food
Personal Toiletries
Whistle

2. Create an emergency stash of Items to keep in your home (in case you are told to stay indoors)

Items to include should be:

Three days’ supply of water
Rule of thumb: a total of one gallon per person per day = 3 gallons per person
Manual (non-electric) can opener
Utensils
Three days’ supply of canned, non-perishable, ready-to-eat food
Canned fruit, beans
Special Needs items:
Infant care items
Items for elderly family members
Items for relatives with disabilities
Items for your pets
Phone that does not require electricity

3. Make a plan – for you and your family

Determine and practice:

Where to go – where is your location to reunite
Church, school, or a community center are ideal public places?
How to find one another
** Each family member must carry contact information
Phone numbers for work, school and each family member
A name a phone number of a relative who lives out of state – they can become your main number to call in case you get separated
How to use different routes to get to your meeting place

4. Stay Informed

Learn what could happen where you live
Learn how to respond to different emergencies
Learn about the emergency plans that your community has set up

1. Approximately 75% of fire related deaths are due to smoke inhalation rather than burns or other injuries.

2. Arson is the leading cause of non-residential structure fires in the United States, followed by electrical distribution systems.

3. Good housekeeping and proper storage of flammables and combustibles are important but often overlooked aspects of fire prevention and safety.

• Waste should not be allowed to accumulate. Combustible or flammable wastes should be removed daily.
• Keep electrical panels, heating devices, and other electrical equipment clear of waste and clutter, especially combustibles and flammables.
• Flammable and combustible liquids should be kept in approved containers. Large quantities of flammable and/or combustible liquids should be kept in approved flammables cabinets.
• Flammable gas cylinders should be stored in a well protected, well ventilated area away from sources of heat or ignition. Cylinders should be properly secured with valve cap protection in place.
• Oxygen cylinders should be stored separately from all flammables.

4. Workplaces must be equipped with an emergency alarm system that alerts employees to fires and other emergencies. The alarm should provide sufficient time for employees to safely evacuate the workplace or area.

5. Emergency alarm systems, fire prevention systems, and fire extinguishing equipment require regular maintenance and testing to verify that they are functioning properly.

6. Emergency evacuation routes and exits must be properly marked and adequately lighted to allow employees to safely evacuate.

7. Emergency evacuation routes and exits must remain clear of obstructions and obstacles at all times.

8. Emergency exit doors must remain unlocked in the direction of exit and should be free of locks or devices that require tools or special knowledge to operate them.

9. Fire extinguishing equipment, including portable fire extinguishers, should only be used by properly trained personnel. Employees required to use fire extinguishing equipment must receive training on an annual basis.

10. Fire prevention and safety are addressed in a number of OSHA regulations, including but not limited to 1910.39 Fire Prevention Plans; 1910.106 Flammable and Combustible Liquids; and 1910 Subpart L Fire Protection.

A friend recently told me that he might be developing an allergy to his office. We laughed about being allergic to work, but since he knows that I am in an industrial hygienist, he was serious about getting my opinion. He asked my thoughts about the source of his allergy. I suggested that he should see if anything new was introduced to his workspace over the winter.

It turns out that his cubicle was located by a wall covered with mold and mildew. This growth had also moved onto his paper files, cubicle and desk surfaces. His employer cleaned up the area and requested laboratory testing of the mold. He doesn’t know the extent of the remediation, but he still is not feeling well.

At the request of his doctor, my friend asked his management for copies of the records of the remediation including what type of mold was found. Management’s reply was that the information was included in company records and could not be released. He asked me if he should insist that his employer provide him with the type of mold that was present – he didn’t realize that he had a legal right to this information under the Occupational Safety and Health Act (OSHA).

Mold Growth

At the request of an employee, an employer is required by OSHA to provide the employee with “Environmental (workplace) monitoring or measuring of a toxic substance or harmful physical agent, including personal, area, grab, wipe, or other form of sampling, as well as related collection and analytical methodologies, calculations, and other background data relevant to interpretation of the results obtained …;” Employers must inform employees of the existence, location and availability of your medical and exposure records when you first begin employment and at least annually thereafter. Employers also must provide these records to an employee or their designated representatives within 15 working days of an employee’s request.

Faced with similar situations, it might be assumed that many people would not know the correct actions to take. To be precise, an employee should make a written request for all information related to the collection and analytical methodologies, calculations, and other background data relevant to interpretation of the results and conclusions from any environmental monitoring or measurements. In this letter to the employer, the employee should state — As required by the US Occupational Safety and Health Administration Standard “Access to employee exposure and medical records. – 1910.1020 “ in section 1910.20(e)(3)(ii ), I anticipate that these records will be available to me for examination and photocopying within 15 working days of this formal request”.

Here is a good summary of the standard

Here is an outline of employee’s rights under OSHA

My family owns property in Canada and I have traveled back and forth many times across the Canadian/US border in the Thousand Island region of upper New York State. Coming back into the US on a Sunday during the 2008 Labor Day Weekend, I was sitting in the passenger seat of our VW Toureg – my wife was driving and my teenage daughter in the back seat. Entering “Customs” (now Border Control of the Division of Homeland Security) is similar to entering a toll booth on a highway, except that you have to drive a gauntlet of various detectors and video equipment 20 feet before you reach the booth housing the DHS agents.

When we reached the booth on this particular day, the DHS agent had a very peculiar look on her face. Without saying a word, she left her booth and slowly walked around our SUV holding a small handheld device pointed at the car. After her completed tour around the vehicle, she returned to her booth to confer with another officer who had just arrived.

As we waited, quite perplexed, she approached us again and, without emotion, asked if any of us had recently undergone any medical treatment. Even more perplexed, we asked why. The agent explained that we had set off the radiation detectors as we approached the booth. I remembered the “nuclear” cardiac stress test I had taken just 12 days before and filled her in, at which point she looked quite relieved and said that probably explains the positive result from the vehicle radiation detectors. Relieved or not, however, this now began the process to determine if this positive trigger of the Homeland Security radiation detectors was a possible security threat!

As a Certified Industrial Hygienist (CIH), I work in the Environmental Science, Safety and Industrial Hygiene consulting field and have been abundantly trained in hazard detection and detector technology, so, all inconveniences aside, I knew I was in the middle of an interesting process. What the DHS folks had to do now was prove that when our vehicle set off the radiation detectors it was indeed nothing more than a harmless security issue, also known as a “false positive”. In our case this was caused because one the vehicle’s occupants was still “glowing” (emitting sufficient radiation energy) from a medical treatment.

Step one – the DHS agents asked me to get out of the vehicle and directed my wife to drive the vehicle through a secondary battery of radiation detectors. The vehicle was clean, so deductively, the radioactive culprit was me!

Step two – I was “invited” into the DHS office where they asked me to sit in a chair next to another agent with yet another handheld radiation meter the size of a loaf of bread.

Step three – he turned on the detector and pointed it at me for approximately 2 minutes. The detector’s LCD display identified the radioisotope as Thallium, which is the isotope used in the cardiac stress tests. The DHS agents were all happy with the results and I was free to continue our trip.

I was impressed with the detection technology being used at our borders to monitor for ionizing radiation. I was also impressed with the ease of use of the detectors being used by the DHS agents who are not trained radiation technicians. It was all fast and accurate. From a security perspective, this is good news and here is why…

Thallium has a half life of 72 hours. This means, 12 days after my stress test, my Thallium dose was barely 7% of the original injected dose. Therefore, internally (in my body) the radioactive energy level remaining from my Thallium injection was at 7% of the original dose.

Additionally, when I set off the detectors, I was sitting in the front seat of a slowly moving SUV, constructed with a significant amount of metal to shield me from the radiation detectors. These detectors were located approximately 4 feet from the vehicle, and still picked up this low level amount of radioactive energy. Either these detectors have impressive sensitively, or I had one significant dose of Thallium during my stress test. I’ll need to research that next.