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Injury & Illness Recordkeeping

The long-awaited revision of OSHA’s Recordkeeping Standard (29CFR1904) is upon us. For the veterinary practice, this rule has only a few changes of note. However, one of the most anticipated changes - increasing the “cutoff” for an exemption for businesses from 10 or fewer workers to 25 or fewer - did not happen.

Some of the changes that affect the profession are:

• The new OSHA Form 300 (Log of Work-Related Injuries and Illnesses) has been simplified and can be printed from your computer on legal-sized paper.
   
• The new OSHA Form 301 (Injury and Illness Incident Report) includes more data about how the injury or illness occurred.
   
• The new OSHA Form 300A (Summary of Work-Related Injuries and Illnesses) provides additional data to make it easier to calculate incidence rates.
   
• Clearer definitions of “work related” are given, including, additional exceptions to the geographic presumption of work relationship; (cases arising from eating and drinking of food and beverages, blood donations, exercise programs, etc. no longer need to be recorded.)
   
• Sections have been added clarifying the work relationship when employees travel as part of their job.
   
• New definitions are included for medical treatment and first aid. First aid is defined by treatments on a finite list. All treatment not on this list is medical treatment.

Until mid-2001, the rules required a separate classification and recording of musculoskeletal disorders (MSDs) and hearing problems. In the most recent rule, OSHA has decided not to modify the form to include a separate column for MSDs.   MSDs are treated like all other injuries or illnesses: they must be recorded if they result in days away, restricted work, transfer to another job, or medical treatment beyond first aid.   Further clarification on the hearing loss column decision is expected soon.

One of the most often misrepresented provisions of the new rule deal with recording all needlestick injuries (click here for more information on the Needlestick Prevention Act and it’s impact on the veterinary profession). Under this recordkeeping rule, only needlestick and sharps injuries involving contamination by another person's blood or other potentially infectious human material are required to be reported and included on the OSHA Form 300.

The annual summary must now be posted for three months (February 1 through April 30) instead of one. In addition, the summary is now a separate form that is completed and must be “certified” by an executive of the practice before posting.

Finally, the new rule requires establishment of a procedure for employees to report injuries and illnesses and for the business to tell their employees how to report these incidents.

Click here for downloadable copies of the new forms.

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The information on these pages is excerpted from The Veterinary Safety & Health Digest and
The Complete Veterinary Practice Regulatory Compliance Manual (5th Edition)  by Philip J. Seibert, Jr., CVT,
Copyright 2003-2001 Philip J. Seibert, Jr., CVT  All Rights Reserved
No part of this publication may be reproduced for distribution without prior permission from the publisher.