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Effective date: Jan. 1, 2002
• Occupational Safety and Health Administration (OSHA) 300: Log of Work-Related Injuries and Illnesses
• OSHA 300-A: Summary of Work-Related Injuries and Illnesses OSHA 301: Injury and Illness Incident Report
• New timelines: Recordable injuries and illnesses must be entered on the OSHA 300 log and 301 incident report within seven calendar days. The annual summary of injuries and illnesses must be posted for three months (instead of one month).
• Record all needlesticks: Needlesticks or sharps injuries that result in exposure to blood or other bodily fluids must be reported. "Clean" sticks — a needlestick with a syringe or sharp that hasn’t been contaminated — need not be reported. Other types of exposures, such as splashes, do not need to be reported unless they result in seroconversion of a bloodborne illness or meet other recording criteria — such as requiring more than first-aid treatment. (See "First aid for injuries," in this issue.)
• Days away from work: You must count the number of calendar days the employee was unable to work as a result of the injury or illness, regardless of whether or not the employee was scheduled to work on those days. Weekend days, holidays, vacation days, or other days off are included in the total number of days, recorded if the employee would not have been able to work on those days because of a work-related injury or illness.
• Protecting privacy: The injured employee’s name may be withheld from the OSHA 300 log in the case of injury or illness to intimate body part or reproductive system; sexual assault; mental illness; HIV infection, hepatitis, or TB; needlestick and sharps injuries; and illness cases where the employee requested to keep their name off. The incident would be marked "privacy concern case." The name would be recorded on the OSHA 301 incident report. However, employee representatives seeking access to information on 301 forms would not receive the employee’s name.
• Record tuberculosis exposures separately: If an employee is occupationally exposed to tuberculosis and subsequently has a positive skin test or a physician’s diagnosis of TB infection, that incident is recorded under a column labeled "respiratory condition." If further investigation shows the TB exposure was not work-related, the incident can be removed.
Proposed delay of provisions
• Hearing-loss recording: Employers would continue to record work-related shifts of an average of 25 dB or more at 2,000, 3,000, and 4,000 hertz (Hz) in either ear on the OSHA 300 Log. When a recordable hearing loss occurs, the audiogram indicating the hearing loss would become the new baseline for determining whether future additional hearing loss by the individual must be recorded. Employers would check either the "injury" or the "all other illness" column, as appropriate. OSHA proposes a year-long delay and reconsideration of a provision that requires employers to check the "hearing loss" column on the OSHA 300 log when an audiogram reveals that a Standard Threshold Shift (STS) in hearing acuity has occurred. An STS is defined as "a change in hearing threshold, relative to the most recent audiogram for that employee, of an average of 10 dB or more at 2,000, 3,000, and 4,000 Hz in one or both ears."
• Musculoskeletal disorder (MSDs) recording: Employers would continue to record disorders affecting the muscles, nerves, tendons, ligaments and other soft tissue areas as they would any work-related injury or illness. Employers would check either the "injury" or the "all other illness" column, as appropriate. OSHA proposes a year-long delay and reconsideration of a provision requiring employers to check an MSD column on the OSHA 300 log for work-related MSD injuries. For record-keeping purposes, the rule defines MSDs as disorders of the muscles, nerves, tendons, ligaments, joints, cartilage and spinal discs that are not caused by slips, trips, falls, motor vehicle accidents, or other similar accidents.