If your company is required to comply with the mandated OSHA standard 29 CFR 1904, then reduce your risk of OSHA imposed citations by maintaining the proper and required written OSHA Recordkeeping documents.
$5,000 to $7,000 is the unadjusted penalty for failure to report to OSHA the death of any employee or the inpatient hospitalization of three or more employees, from a work-related incident.
$7,000 is the maximum penalty for failure to make available the OSHA 301 forms ($1,000 per form), when requested by any employee, former employee, personal representative, or authorized employee representative.
$1,000 is the unadjusted penalty if an employer fails to post the OSHA 300A Summary.
OSHA’s 300 Log
Not all injuries / illnesses are recordable on the log. You must determine if the case is “work related” and meets the criteria for a recordable case.
Examples of injuries / illnesses that occur in the work environment but are not work-related, therefore not recordable:
injury / illness results from voluntary participation in a wellness, fitness or recreational program.
injury / illness is solely the result of an employee eating or preparing food for personal consumption.
injury / illness is solely the result of personal grooming or self medication.
First aid cases are also not recordable, even if the employee has been sent to the hospital. Some examples include:
removing foreign bodies from the eye using only irrigation
administering tetanus immunizations
using hot / cold therapy
visits to the physician solely for observation for counseling
diagnostic procedures such as x rays and blood tests
Some employers record everything “just to be safe”. Why is this a problem? Because too many incidents for your Standard Industry Code (SIC) may trigger an OSHA inspection!
OSHA’s 301 form
Complete an OSHA 301 or an equivalent form for each recordable injury or illness. Many employers use their insurance company’s incident investigation form as an equivalent.
OSHA’s 300 - A form
The annual summary must be completed and certified (signed) by a company executive. You must post a copy of the annual summary in a conspicuous place where notices to employees are customarily posted. The annual summary must be posted no later than February 1st and remain posted until the end of April.
Retention
All forms must be retained for five (5) years following the end of the calendar year that these records cover. So, your 2008 records must be kept until 2013!
Summary
Every year, the U.S. Occupational Safety and Health Administration
sends letters to approximately 80,000 employers across the country
requesting their injury and illness data from the previous year. From this data, OSHA picks 14,000 workplaces with the highest incident rates. Not only are these
workplaces listed on OSHA's website, but from the 14,000 workplaces
listed, 4,500 are then targeted for wall-to-wall inspections.
As we begin a new year I cannot overestimate the importance of accurate recordkeeping. Too many employers either don’t record injuries or record injuries that don't need to be recorded ... skewing their incident rate and making their safety performance appear questionable.
About the Author
Sunny Corona, is Managing Member of Custom Safety Services, LLC and is a Certified Safety Professional with 25 years in the safety field. Custom Safety Services is a safety consulting / training firm specializing in workplace violence/sexual harassment, office /industrial ergonomics, OSHA compliance, Fleet Safety Programs and Return to Work Programs . Contact Sunny@CustomSafetyServices.com or 201-703-6966. http://www.customsafetyservices.com/
Wednesday, January 21, 2009
OSHA Recordkeeping
Saturday, January 17, 2009
Thursday, January 15, 2009
Early Return to Work Programs: The Second Best Tool for Controlling Workers’ Compensation Costs
Why Have an Early Return to Work Program? Second to accident prevention efforts, an Early Return to Work (ERTW) Program is management’s best tool to minimize the financial cost of a Workers’ Compensation claim. The key word is “Early”. Your actions upon notification of illness or injury have a profound impact on the outcome of most cases. ERTW actions should start as soon as possible. Statistics and Facts about Return to Work: An ERTW Program will have a direct impact on your Workers’ Compensation premium for the next three years! Typically, an injured employee, of a company without an ERTW Program, will contact an attorney within two weeks after injury.
Studies show that 80% of all litigated claims result in higher settlements. Employees who retain an attorney see an average of 5.2 doctors. Those who do not retain an attorney are treated by an average of 2. Studies also show the chance of litigation is reduced by 50% if the employer maintains contact with the injured employee which reinforces the worker’s self image and value to the company. Returning an injured employee to the workplace reduces associated recovery costs, including medical expenses, rehab expenses, therapy and surgical expenses. Often the percentage of permanent impairment is significantly reduced. Injured employees off work longer than six months have only a 50% chance of every returning to their job; if lost time exceeds one year, their chances decrease to less than 10%!
Objectives of Return to Work Programs: Return to work objectives should include the following:
Reduce the number of cases entering the workers’ compensation litigation system. Decrease the number of lost work days.
Increase employee morale and motivation to return to and remain at work.
Facilitate temporary or permanent job reassignment or job restructuring.
Identify alternative employment consisting of modified duties.
Types of Alternative Work Activities: An employee who is off work for a sustained period of time will lose interest in his/her job and be less effective upon return to work. The main idea is that the employee moves from a placid environment, where the disability is the reason for being at home or off work, back to a productive environment. At work, the employee’s mind is busy with production, and the productive atmosphere fosters positive thoughts.
Modified Work
Modified Work is when an employee is brought back to work and placed temporarily within an existing job that is not as physically taxing or demanding as their normal job.
Restricted Work
Restricted Work is when an employee is brought back to their normal job with restrictions assigned by a physician, i.e. lifting no more than 30 lbs., six times per hour, standing no more than two hours, etc.
Modified or Total Accommodation
This is when positions are specifically created which will accommodate the restrictions of the injured employee.
Job Function Analysis: You should develop a Job Function Analysis, which is an extension of the Job Description and its purpose is to:
Describe tasks and physical demands of the regular job.
Develop a task inventory which can be used to fill the work day, for an injured employee.
Allows the supervisor a broad selection from which to choose and accommodate many different types of injuries.
Be used by the treating physician to determine job limitations.
Why Use a Managed Care Facility?
Statistics show that the longer an injured employee is off work, the greater the total cost of that case. This is where Concentra is a huge benefit. Concentra provides occupational healthcare services that employers need to keep safe and healthy workforce.
Each patient medical encounter is an opportunity to measure the effectiveness of our treatment procedures and our management processes from the first visit to case closure. Customers who have provided total claim cost data for comparative result studies have discovered that injuries not treated by Concentra have higher average total claim costs. The study results indicate that Concentra saves employers up to 52% per claim when compared to other providers in the study.
To find real solutions, look to Concentra:
Dynamic Early Intervention Model Exercise-based therapy with functional outcomes Workers return to work with a reduced risk of re-injury
Your employees will receive high-quality healthcare from specialists that understand your occupational healthcare needs. Better care and better outcomes mean a better bottom line for everyone.
Conclusion
Assign someone enthusiastic to oversee your ERTW Program.
Analyze injury statistics to determine problem areas and then meet withsupervisors to analyze and document modified duty tasks within existing job descriptions, prior to an injury.
Ensure that all tasks are important to your operation and productivity.
Communicate the goals and rationale of the program to all supervisors and employees so that everyone know how it works and how they fit into the plan.
Evaluate the program on a regular basis and make adjustments as necessary.
About the Authors
Sunny Corona, is Managing Member of Custom Safety Services, LLC and is a Certified Safety Professional with 25 years in the safety field. Custom Safety Services is a safety consulting / training firm specializing in workplace violence/sexual harassment, office /industrial ergonomics, OSHA compliance Fleet Safety Programs and Return to Work Programs . Contact Sunny@CustomSafetyServices.com or 201-703-6966.
Orlando Vasquez is a Health Services Manager with Concentra Medical Centers, who have 8 locations in Northern NJ and over 300 locations nationwide. Contact Orlando_vasquez@concentra.com or 201-206-4554.
