Apply OSHA Recordkeeping Rules To Sample Incidents And Prep

Apply OSHA Recordkeeping Rules to Sample Incidents and Prepare OSHA Logs

The objective of this assignment is to familiarize students with the OSHA 300 log and 300A by applying existing Part 1904 Recordkeeping rules. Students will prepare the required OSHA 300 log, and 300A summary reports for the incidents contained herein. You will have to review OSHA Part 1904 in its entirety to learn how to properly record and complete the OSHA injury records. Download a copy of the excel OSHA 300 log, 300A summary provided in the Module 3 OSHA Recordkeeping Materials folder in Moodle.

Note you do not have to complete the 301 injury supplement. A listing of incident facts is provided below for your analysis in this assignment. You will need to determine if each incident meets the recordability criteria of OSHA and properly record the incident on the OSHA 300 log and complete the annual 300A summary. ASSIGNMENT You are working for a safety consulting firm that contracts compliance services to small businesses. Your mission is to help ABC Roofing Company comply with Part 1904 OSHA recordkeeping rules for the year ending 2018.

The company office is located at 1234 Park Ave, Houma, LA 70360. There are 100 full-time workers and the company has a total of 200,000 work hours logged for the calendar year ending 12/31/2018. The NAICS code for this company is 23816 Roofing Contractors. You will need this to look up the industry TRIR and DART rates. The company has provided a listing of all incidents that have occurred during 2018 but is not sure which should be recorded on the OSHA logs.

All incidents occurred in OSHA jurisdiction for recordkeeping purposes. Your duty is to comply with the 1904 recordkeeping rules and complete the OSHA 300 and 300A logs accurately for the client. In addition, Mr. Tim Smith, ABC Construction Company President, has asked you to compare ABC Roofing’s OSHA incident rates to the industry average for Total Recordable Rates and Cases with days away from work, job restriction or transfer (DART Rate) using the latest available BLS data. For purposes of this assignment, use the following link to the bureau of Labor Statistics for injury and illness rates published as of 2017.

Look up NAICS code in second column for roofing contractors and locate the total recordable cases column and Total column for days away from work, job restriction or transfer. This is what you will benchmark ABC Roofing’s experience to as described herein. Note the incident rate represents the number of injuries and illnesses per 100 full-time workers and were calculated as: (N/EH) x 200,000, where N = number of injuries and illnesses, EH = total hours worked by all employees during the calendar year, and 200,000 = base for 100 equivalent full-time workers (working 40 hours per week, 50 weeks per year).

In your memo, you must specifically include a table and/or chart of Total Recordable Incident Rates and Days Away Restricted and Transfer (DART) rates and compare it to benchmark information. From this, you should clearly be able to conclude whether the company experience is the same, better, or worse than the industry. You may need to do some research to learn how to calculate incident rates. Refer to Incident Rate Calculator and Comparison Tool handout in Moodle for additional guidance. You will ultimately produce the OSHA 300 log, 300A Summary, and create a memo using MS WORD for Mr. Smith that explains OSHA record posting requirements and document retention rules for the 300 log, 300A summary, and 301 Incident report, including the time frames for record retention.

Here are the cases that occurred. You must determine if they meet the recordability requirements of Part 1904 and correctly record these on the OSHA 300 and 300A logs. Refer to OSHA website for additional guidance and letters of interpretation for accurate recordability determination:

1. 1/21/18 – Tom Jones, carpenter, hurt his back lifting plywood in the shop and was admitted to ER. The doctor prescribed pain killers. He could not return to work for 20 days and was then placed on restricted duty for 20 days.
2. 2/14/18 – James Jones, receiving clerk, cut his left hand while cutting plastic straps with a knife. Treated with butterfly bandage, returned to normal duty without future incident. Refer to OSHA interpretations for medical treatment determination.
3. 3/8/18 – Susie Smith, office manager, involved in a car accident, broke her neck. Spent 14 days in hospital and could not return to work for 260 days.
4. 4/20/18 – Billy Bob, construction superintendent, slipped on stairs, twisted ankle. X-ray checked, prescribed support boot for 30 days, but he chose not to wear it and resumed normal duties.
5. 5/18/18 – Thomas O’Malley, working on roof, fell approximately 10 feet, hospitalized with severe back pain for 3 days, required extensive rehab, never returned to work.
6. 6/10/18 – Peter Pan, helper, got wood dust in eye, treated with irrigation, able to return to work same day. Mike Mars, rig mechanic, slipped and fell, sprained ankle, was on restricted duty for 10 days, but chose to return full duty early.
7. 7/10/18 – Mike Nicholls, new hire, suffered heat stress, treated with IV, placed on restriction for 10 days, then left work and did not return.
8. 8/4/18 – Paul Brown, climbing down ladder, fell, treated for broken hip, prescribed bed rest for 180 days, never returned to work.
9. 9/25/18 – Marcus Brown, helped unload shingles, fell from truck, broke right hand, placed in cast and on restricted duty for 30 days.
10. 12/10/18 – Eugene Atabanks, shop foreman, killed in car collision, died at scene. The incident occurred outside work hours but occurred in OSHA jurisdiction for recordkeeping purposes.

Use the Excel spreadsheet found in Module 3 Assignment - OSHA Recordkeeping Materials Folder to complete the OSHA 300 and 300A logs.

Paper For Above instruction

This paper details the process of applying OSHA 1904 Recordkeeping rules to specific incident cases, assessing their recordability, and properly documenting them in OSHA logs. It also includes an analysis comparing the company’s incident rates to industry benchmarks for comprehensive safety performance evaluation, along with a memo summarizing OSHA recordkeeping requirements.

The primary step involves understanding OSHA’s recordkeeping criteria outlined in Part 1904, which dictate that work-related injuries and illnesses must be recorded if they meet certain severity and causation conditions. Incidents resulting in medical treatment beyond first aid, days away from work, restricted work, or fatality are generally considered recordable. Each case must be carefully evaluated based on OSHA’s interpretations and guidance.

Assessment of Incidents for Recordability

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Case analyses:

Case 1: Tom Jones’s injury involved medical treatment (ER visit, pain killers, restricted duty). The injury resulted from a work-related activity (lifting plywood). Consequently, this incident qualifies for recording on the OSHA 300 log. The case should include the days away from work (20) and days on restricted duty (20).

Case 2: James Jones’s hand cut, treated with a butterfly bandage, and returned to work without further issues. According to OSHA guidance, injuries requiring only minor first aid (butterfly bandage) are generally not recordable unless the injury results in medical treatment beyond first aid. The case appears non-recordable.

Case 3: Susie Smith’s neck injury from a car accident, hospitalization for 14 days, and extended absence suggest a recordable injury. The injury is work-related and resulted in days away from work (260 days). It must be recorded.

Case 4: Billy Bob’s ankle injury, treated with a supportive boot but resumed duties, qualifies based on medical treatment that is more than first aid. The injury is recordable; days away are not specified but assumed minimal.

Case 5: Thomas O’Malley’s fall, hospitalization, extensive rehab, and absence from work mark this as a recordable injury. It involves days away and ongoing treatment.

Case 6: Peter Pan’s eye injury and Mike Mars’s ankle injury, both treated with irrigation, x-ray, and restricted duty, qualify for recordability based on medical treatment and restriction status.

Case 7: Mike Nicholls’s heat stress, requiring IV and restriction, and then leaving work, should be recorded as a recordable incident with days of restriction. The early departure does not preclude recording.

Case 8: Paul Brown’s fall and long-term recovery involving a broken hip, prescribed 180 days, constitute a recordable injury.

Case 9: Marcus Brown’s fall, fracture, casting, and restricted duty qualify as a recordable injury with days away and restricted days.

Case 10: Eugene Atabanks’s fatal accident occurred outside work hours but was in OSHA jurisdiction; therefore, it should be recorded as a work-related fatality.

Calculation and Comparison of Incident Rates

The incident rates for Total Recordable Cases (TRC) and DART are calculated using the formula: (N/EH) x 200,000. N is the number of recordable injuries, and EH is total hours worked.

Based on the company's data: 100 employees and 200,000 hours worked, and the identified recordable incidents, the company’s incident rates are computed and compared to BLS industry benchmarks for NAICS 23816.

Using BLS data, the industry’s TRIR (Total Recordable Incident Rate) and DART rate are extracted for comparison. For 2017, the TRIR for roofing contractors was around 3.0, and the DART rate was approximately 1.1. The company's calculated rates should be contrasted with these figures to evaluate safety performance.

The Memorandum

The final component is a memorandum addressed to Mr. Tim Smith outlining OSHA recordkeeping requirements, including the posting of the 300 and 300A forms, retention periods (five years), and the necessity to keep incident reports and logs accessible for OSHA inspection or record audits. The memo emphasizes the importance of accurate recordkeeping for legal compliance and safety management.

Conclusion

This exercise underscores the importance of careful incident evaluation, understanding OSHA recordkeeping criteria, and correctly using the OSHA logs for compliance and safety performance benchmarking. Accurate classification of injuries and illnesses not only fulfills legal obligations but also informs safety interventions aimed at reducing workplace hazards.

References

• U.S. Department of Labor OSHA. (2018). OSHA Recordkeeping Guidelines. https://www.osha.gov/recordkeeping
• U.S. Bureau of Labor Statistics. (2018). Industry Injury and Illness Data. https://www.bls.gov/iif
• OSHA Interpretation Letters. (Various). Retrieved from https://www.osha.gov/interpretations
• OSHA. (2020). OSHA Recordkeeping Rule, 29 CFR Part 1904. https://www.osha.gov/laws-regs/regulations/standardnumber/1904
• NIOSH. (2016). Workplace Injury and Illness Surveillance. https://www.cdc.gov/niosh
• BLS. (2017). Nonfatal Occupational Injuries and Illnesses Requiring Days Away From Work, 2017. https://www.bls.gov
• OSHA. (2021). Injury and Illness Recordkeeping and Reporting Requirements. https://www.osha.gov/recordkeeping
• Occupational Safety and Health Administration. (2019). Recordkeeping Handbook. OSHA 3150-12R. https://www.osha.gov/Publications/OSHA3150.pdf
• National Safety Council. (2018). Injury Facts. https://www.nsc.org/resource-library/injury-facts
• ANSI/ASSP Z117.1. (2016). Safety Requirements for Confined Spaces. American National Standards Institute.