Forms.Recordkeeping

As new practices are introduced to prevent indoor air quality problems, an organized system of recordkeeping will help those practices to become part of routine operations and to "flag" decisions that could affect lAQ. The best results can be achieved by taking time to think about the established channels of communication within your organization, so that new forms can be integrated into decision making with minimum disruption of normal procedures. 

In an interference, the proof requirements are very important. Activities or evidence given by the inventor must be collaborated in some manner. This is best accomplished through evidence from non-inventors, although other forms of evidence have been used successfully in some cases. For this reason, research organizations have policies and procedures governing notebook recordkeeping in their laboratories. 

See Chapter 7, Reporting and Recordkeeping. EPA has issued reporting rules covering specific uses of chemical substances and has the authority under TSCA 8 to issue rules concerning specific physical forms of chemical substances. 

Safety Resources Support Table FMCSA Accident Countermeasures FMCSA Recordkeeping Requirements Sample Drug Alchohol Policy Sample DOT Forms... 

Note Many states have their own OSHA-approved occupational safety and health programs. Contact your state s labor department to determine if you should comply with the federal OSHA regulations or your state s requirements. Most states follow the same recordkeeping requirements and use the same forms as the federal regulations. Also note that some insurance companies have their own forms that you can use instead of the OSHA forms. Check with your insurance carrier for information. 

Develop a recordkeeping system to record and track all injuries and illnesses in the workplace. Keep one set of records for OSHA compliance — using Forms 300, 300A, and 301 — and one set that is for your eyes only, containing more detailed information about all incidents. 

Employees, former employees, and th r representatives have the right to review the OSHA Form 300 in its entirety. They also have limited access to the OSHA Form 307 or its equivalent. See 29 CFR Part 1904.35. in OSHA s recordkeeping rute. for further details on the access provisions for these forms. 

According to Public Law 91-596 and 29 CFR 1904, OSHA s recordkeeping rule, you must keep this form on file for 5 years following the year to which it pertains. 

Although there are many kinds of incident and injury recordkeeping requirements and forms, the most commonly known system is that of the Occupational Safety and Health Administration (OSHA) and the Bureau of Labor Statistics (BLS). It provides a detailed example of incident record keeping. Details of the OSHA record-keeping requirements appear in 29 CFR 1904. They may change from time to time. 

Jamie Smith is discouraged by the recordkeeping requirements of the company. She keeps forms for OSHA and an additional form for workers compensation requirements. When a compliance officer arrives for a routine inspection, she is surprised to learn that she does not have to keep all the forms. She is also surprised to learn a form must be posted during the months of February through April. She has not posted the form in the past, but now assumes she should after the comment made by the compliance officer. The biggest surprise arrives three months later when the company receives a citation because the appropriate company official did not sign the form. 

A) Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed healthcare professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes) ... 

Under the recordkeeping requirements established by the Occupational Safety and Health Administration and adopted by virtually all of the state plans, the work-related injury or illness is required to be recorded on the OSHA provided forms. However, safety and health professionals should be aware that the criteria through which a work-related injury or illness becomes recordable is substantially narrower than that of a workers compensation claim. A work-related workers compensation claim in which monies are spent by the employer may not meet the criteria to become an OSHA recordable case. Thus, given the different criteria between workers compensation and OSHA, the same injury or illness could potentially be a difference, depending on which system is being evaluated. 

In addition to the OSHA 300 log, OSHA has two other documents that must be completed within the recordkeeping requirements. For each injury recorded on the OSHA 300 log, the employer is responsible for completing the OSHA 301 form. This document is commonly referred to as an incident investigation form. Here the employer will record specific information regarding the incident, such as what work the employee was performing, what occurred, and what caused the injury. OSHA... 

This applies to any employer who is required to maintain a log of occupational injuries and illnesses under OSHA s injury and illness recordkeeping standard, part 1904. However, employers may use the OSHA 300 Log and 301 incident report to meet the sharps injury log requirements. To use the recordkeeping forms, the type and brand of the device has to be entered on either the 300 or 301 form, and the records must be maintained in a way that segregates sharps injixries from other types of work injuries. However, if you prefer to maintain a separate sharps injury log, there is a sample form on page 77 of this chapter. 

If your company is covered by this rule, you will need to start documenting workplace injuries and illnesses according to the revised Part 1904 requirements. And, you will begin using a new set of recordkeeping forms, the OSHA 300 series. 

This chapter is your compliance guide through the regulatory maze of injury and illness recordkeeping. Use it to determine if your company is covered and if so, how to document and maintain accurate records of employees work-related injuries and illnesses. Also, at the end of the chapter, you will find copies of the new forms you are required to use. 

If you decide to voluntarily disclose the recordkeeping forms to persons other than government representatives, employees, former employees or authorized representatives, remove... 

Even if you are exempt from keeping injury and illness records, the BLS may inform you in writing that it will be collecting injury and illness information from you in the coming year. If you receive such a letter, you must keep the injury and illness records required by OSHA s recordkeeping rule and make a survey report for the year covered by the survey. All employers who receive a survey form must respond to the survey, even those in state-plan states. 

Q. May employers attach missing information to their accident investigation or workers compensation forms to make them an acceptable substitute form for the OSHA 301 for recordkeeping purposes ... 

This approach is consistent with the no-fault recordkeeping system OSHA has historically adopted, which includes work-related injuries and illnesses, regardless of the level of employer control or non-control involved. The concept of fault has never been a consideration in any recordkeeping system of the U.S. Department of Labor. Both the Note to Subpart A of the final rule and the new OSHA Form 300 expressly state that recording a case does not indicate fault, negligence, or compensability. 

Despite the fact that only the Summary Form 300A is required to be posted, some employers apparently have posted both the Form 300 and Form 300A in the workplace. The writer suggests that further clarification is needed with the recordkeeping forms or elsewhere, making clear to employers that the Form 300 shordd not be posted along with the Summary Form 300A. 

The instructions that accompany the OSHA recordkeeping forms do include the following Question and Answer When must you post the Summary You must post the Summary only — not the Log — by February 1 of the year following the year covered by the form and keep it posted until April 30 of that year. ... 

OSHA discussed the issue of therapeutic exercise in the preamble to the final rule revising OSHA s injury and illness recordkeeping regulation. OSHA stated that it considers therapeutic exercise as a form of physical therapy and intentionally did not include it on the list of first aid treatments in Section 1904.7(b)(5)(ii). Section 1904. 7(b)(5)(ii)(M) states that physical therapy or chiropractic treatment are considered medical treatment for OSHA recordkeeping purposes and are not considered first aid. Section 1904.7(b)(5)(iii) goes on to state that the treatments included in Section 1904. 7(b)(5)(ii) is a comprehensive list of first aid treatments. Any treatment not included on this list is not considered first aid for OSHA recordkeeping purposes. 

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