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On the Recording – Reporting of Occupational Injuries and Illness [29 CFR 1904]

By Pati Trites; MPA, CHBC and CPC

In this era of eHRs, and eMRs, it is vital to understand how OSHAs Recording and Reporting of Occupational Injuries and Illnesses Standard [29 C.F.R. 1904 – also known as the Recordkeeping Standard] requires employers to record & report work-related fatalities, injuries and illnesses www.HealthcareFinancials.com

Exemptions

For example, in January 2001, OSHA provided for a partial exemption from this Standard for many industries including: Offices & Clinics of Medical Doctors, Offices and Clinics of Dentists, Offices of Osteopathic, Offices of Other Health Practitioners, Medical and Dental Laboratories, and Health and Allied Services, Not Elsewhere Classified [1].

The exemption applies as long as the above-stated employers do not have at least one of the following events occur:

• any workplace incident that results in a fatality; or
• the hospitalization of three or more employees (example: a malfunctioning heat exchanger on a furnace causes carbon monoxide poisoning to the employees. If three or more must be hospitalized, then the exemption is lost for the calendar year).

If either of these two events occurs then the practice must comply with the reporting requirements of this Standard. Again, each employer who is physically located in one of the 26 states that has its own OSHA must follow state requirements if they are stricter.

Fatality or Hospitalization

In the event of a workplace fatality or an incident that causes the hospitalization of three or more employees, the employer must notify OSHA’s Area Office nearest to the site of the incident either in person or by phone. Notification can also be made by calling the OSHA toll-free central telephone number, 1-800-321-OSHA (1-800-321-6742). This notification must be accomplished within eight hours of the occurrence [2].

OSHA Form 330

Although the likelihood of either of these occurrences taking place is slight, it may be prudent to maintain records that comply with the OSHA Recordkeeping Standard in the event the practice’s partial exemption is lost during a calendar year. Keeping adequate records includes maintaining an OSHA Form 300, which is a log of the following events: days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, and a significant injury or illness diagnosed by a physician or other licensed healthcare professional.

OSHA Form 330-A

If the practice maintains its partial exemption throughout the calendar year, nothing further needs to be done. But if the practice loses its partial exemption this form must be used to complete a second OSHA form, Form 300A, the annual summary. The employer must post a copy of Form 300A in each practice location (if there are multiple locations) in a conspicuous place or places where notices to employees are customarily posted. The employer must also ensure that the posted annual summary is not altered, defaced, or covered by other material. The Form 300A remains posted from February 1 through April 30 of the calendar year following the year of data collection [3]. In other words, for all records kept in 2005, Form 300A would be posted from February 1, 2006, through April 30, 2006, and so on.

Assessment

An additional recordkeeping requirement for healthcare entities is established in the Bloodborne Pathogen Standard, wherein the Sharps Injury Log must be maintained by any employer who must comply with the Recordkeeping Standard. If the employer loses his or her partial exemption during the year, then there is an obligation to complete and maintain the Sharps Injury Log. Again, this is a form that probably should be maintained by all healthcare organizations just in case the partial exemption is lost in any particular year.

Conclusion

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1.  29 C.F.R. 1904 Subpart B Appendix A.

2.  29 C.F.R. 1904.39.

3.  29 C.F.R. 1904.32.

Filed under: "Doctors Only", Health Law & Policy, Practice Management, Professional Liability, Quality Initiatives | Tagged: 29 CFR 1904, EHRs, EMRs, OSHA, OSHA Form 330, OSHA From 330A, Pati Trites, Recording and Reporting of Occupational Injuries and Illnesses Standard, worman's compensation | 1 Comment »