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Mishap Reporting & Recordkeeping Seminar 11 March 2010

Professional Development Conference. 18 th Annual Safety PDC. Mishap Reporting & Recordkeeping Seminar 11 March 2010. Session Objectives. Mishap Recordkeeping OSHA 29 CFR 1904 and 1960 Sample Mishap Recording Scenarios Overview of DoD 6055.7 & DoN 5102.1 Mishap Reporting

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Mishap Reporting & Recordkeeping Seminar 11 March 2010

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  1. Professional Development Conference 18th Annual Safety PDC Mishap Reporting & RecordkeepingSeminar11 March 2010

  2. Session Objectives • Mishap Recordkeeping • OSHA 29 CFR 1904 and 1960 • Sample Mishap Recording Scenarios • Overview of DoD 6055.7 & DoN 5102.1 Mishap Reporting • Brief review of mishap reporting reqmts • WESS Design Goals & Vision • New WESS Aviation Mishap Module • Customer Brainstorming and Feedback Forum

  3. Injury and Illness Recordkeeping Contact Information Installation & Industrial Safety Programs Naval Safety Center 757-444-3520 x7157 Safe-OSHfdbk@navy.mil WESS Help Desk 757-444-3520 x7048

  4. Mishap Recordkeeping Federal Agency Recordkeeping for Injuries and Illnesses

  5. Overview of OSHA Recordkeeping • How federal agencies record their injuries and illnesses • OSHA’s Recording and Reporting Occupational Injuries and Illnesses Standard 29 CFR Part 1904 • Revised 29 CFR 1960 adopts the 1904 recordkeeping rules

  6. 29 CFR Part 1904 • Establishes comparable data • Federal agencies vs. private sector • Improves data accuracy and quality • Tracks occupational injuries and illnesses • Improves safety & health program mgmt. • Does not establish fault or that violation of any OSHA regulation occurred. • OSHA recordkeeping and Workers’ Compensation are independent of each other.

  7. What this means for DoN Commands • When an injury/illness occurs you now must determine • Did an injury/illness occur? • Is it work related? • Is it a new case? • Is it recordable (on the OSHA Log)? • Is it reportable (in WESS/ESAMS)? • You must maintain an OSHA 300 Log • You must prepare annual OSHA 300A Summary and post from 1 Feb. through 30 April in your workplace.

  8. First, some terminology • Work-relatedness • See the next several slides • Recordable • We recordinjuries/illnesses on the OSHA 300 Log • Reportable • We report injuries/illness in WESS or ESAMS • Compensable • Injuries/illnesses are compensable when the Office of Workers Compensation Program (OWCP) determines if a case is compensable (not the Command).

  9. Occupational Safety & Health Administration Introduction to 29 CFR Part 1904 OSHA’s Recordkeeping Standard

  10. Determining Work-Relatedness (1904.5) • An event or exposure in the work environment • Either caused or contributed to the resulting condition • Significantly aggravated a pre-existing injury or illness • Injuries and illnesses occurring in the work environment are generally presumed to be work-related, unless they fit into one of OSHA’s nine exceptions. [1904.5(b)(2)]

  11. Exceptionsto Work-Relatedness [1904.5(b)(2)] Present as member of general public Symptoms arising in work environment, solely due to non-work-related event or exposure Voluntary participation in wellness program, medical, fitness, or recreational activity Eating/drinking or preparing food/drink for personal consumption Personal task outside assigned working hours Personal grooming, self-medication for non-work-related condition, or intentionally self-inflicted Motor vehicle accident in parking lot/access road during commute Common cold or flu Mental illness unless medical opinion states work-related

  12. What if an employee is injured working at home? • Considered work-related if • Injury or illness occurs while employee is performing work for pay/compensation in the home, e.g. telecommuting • However, if employee trips over the family dog while running for a business phone call, or is shocked by faulty home electrical wiring, it is not work-related.

  13. Is it a New Case? • New Cases – Defined • No previous recorded injury of the same type affecting the same part of the body; or • Person had fully recovered from a previous injury & a work-related event caused recurrence • Then ask • Is it recordable? – If yes, it goes on the OSHA 300 Log • Is it reportable? – If yes, then a WESS or ESAMS entry is made

  14. Is it a First Aid Case? [1904.5(b)(5)(ii)] Use of non-Rx meds at non-Rx strength Tetanus immunizations Cleaning, flushing or soaking skin surfaces Use of bandages, gauze pads, Steri-strips or butterfly bandages. Hot or cold therapy Use of non-rigid means of support – elastic bandages, wraps, etc. Use of temporary immobilizing devices – splints, slings, neck braces, etc. Drilling a nail to relieve pressure or drain fluid Use of eye patches Removing foreign bodies from the eye(s) by flushing or swabs. Removal of splinters from skin by irrigation, tweezers, swabs, etc. Using finger guards Using massages (Physical therapy or chiropractic treatment is medical treatment.) Drinking fluids for relief of heat stress

  15. Is it a First Aid Case? • First aid is defined using a finite list of treatments, regardless of the credentials of the provider and such cases are not recordable. • All other treatment is now considered medical treatment. • The regulation also clarifies the recording of "light duty" or restricted work cases. • Record cases when injured/ill employee only works partial days or is restricted from his or her "routine functions." "Routine functions" are defined as work activities the employee regularly performs at least once weekly.

  16. Once it’s work-related, is it recordable? • OSHA’s six general criteria that make an injury/illness recordable • Death • Days away from work • Restricted work or job transfer • Medical treatment beyond first aid • Loss of consciousness • Diagnosis by a physician or other licensed health care professional as a significant injury or illness

  17. 1904 Injury/Illness Recording Criteria Did the employee experience an injury or illness? NO Was a CA-1/2/6 filed with HR / OWCP? YES YES NO Is the injury or illness work-related? Update the previously recorded injury or illness entry on the 300 Log, if necessary YES NO Is the injury orillness a new case? YES X Does the injury or illness meet the general recording criteria or the additional criteria? Record the injury or illness on the 300 Log YES NO Do not record the injury or illness on the 300 Log

  18. Explaining the OSHA Recording Rules Mishap Scenarios Lets look at some sample cases and determine whether they should be recorded.

  19. Step 1 – Did an Injury/Illness Occur? • Employee reports to medical with complaint of painful wrists. Given 2 Advil and returned to job. • Did an injury occur? • Yes – Painful wrists was the injury experienced. Proceed to next step. • A chlorine gas leak occurs and 2 employees in the area are rushed to the hospital. Told to stay home the next day as a precautionary measure. • Did an injury occur? • It Depends. We need more information. • If either employee exhibited signs/symptoms, then Yes – Proceed to next step. If not, Stop.

  20. Step 2 – Is it Work-Related? • Employee gives blood at voluntary Blood Drive and passes out – Loss of consciousness • No – This is not work-related • Voluntary participation in a wellness program, a medical, fitness or recreational activity, etc. is an exception to the rule. • Employee sprains ankle in the parking lot while walking in to work. • Yes – No exception applies. Parking lot exception only applies to motor vehicle accidents while commuting. • Employee slips and falls in hallway, breaking arm, while working on daughter’s science project on day off. • No – This is not work-related. • Injury is the result of doing personal tasks, un-related to the job, in the workplace, but outside of normal working hours.

  21. Step 3 – Is it a New Case? • 5 Weeks ago, employee sprained wrist at work. Rec’d support, prescription medication and “light duty”. Two weeks ago, employee returned to full duty. Today, he complains of pain in same wrist while moving boxes. • Yes, go on to next step. Employee had completely recovered. • Same scenario as above, employee returned to work two weeks ago, but continued to take prescription medication. • No, this is not a new case. Update previous recorded log entry. • Employee fractured foot at work. Every 6 months or so, it bothers him and he is placed on light duty for 1 or 2 days. • Cannot determine without more information. • If the employee had completely recovered from the previous injury, then this is a new case. If not, update the previous record. • If completely recovered, did a new event or exposure occur in the work environment? If yes, then this is a new case.

  22. Step 4 – Does it Meet any Recording Thresholds? • OSHA 29 CFR 1904.7-1904.11 • Fatality • Days away from Work (1 or more lost work days) • Days of Restricted Work Activity • Includes light/limited duty, partial work days (< 1 LWD) • Transfer to another Job (temporary or permanent) • Medical Treatment beyond First Aid • Loss of Consciousness (work-related) • Significant Injury/Illness diagnosed by PLHCP • Special Cases • Includes Hearing loss, Sharps, TB, etc.)

  23. Recording Special Cases

  24. Recording Needlesticks (1904.8) • Record all workplace cut and puncture injuries resulting from contaminated (or reasonably anticipated to be contaminated with blood or other potentially infectious materials that may lead to bloodborne diseases) sharps. • These diseases include Acquired Immunodeficiency Syndrome (AIDs), hepatitis B and hepatitis C. • Does not require all cuts and punctures to be recorded. For example, cut from a knife that was not contaminated (by blood) would not be recordable if only first aid was used to treat it.

  25. Medical Surveillance Removal (1904.9) • In addition, record an injury or illness case on the OSHA 300 Log when the employee is medically removed under the medical surveillance requirements of any OSHA standard. • E.g. Blood lead tests average 50ug/100g sample. • If the removal is precautionary solely to prevent further exposure and no standard was exceeded, the case is not recordable.

  26. Hearing Loss (1904.10) • Revised the criteria for recording work-related hearing loss beginning January 1, 2003. • Must be recorded when hearing testing reveals employee experienced a work-related Standard Threshold Shift (STS) in one or both ears and the employee's total hearing level is 25 dB or more above audiometric zero in the same ear as the STS. • OSHA issued new recordkeeping forms requiring employers to check the hearing loss column on the OSHA 300 Log beginning January 1, 2004.

  27. Tuberculosis (1904.11) • Must record a case when an employee is exposed to someone with a known case of tuberculosis, and that employee subsequently develops a tuberculosis infection.

  28. Musculoskeletal Disorders (MSDs) • OSHA decided NOT to include separate column for MSDs on the Log and Summary forms. • This has no effect on our obligation to record all cases meeting the requirements of ¶ 1904.4-1904.7. • If a musculoskeletal disorder is work-related, is a new case, and meets one or more of the general recording criteria, it must be recorded. • For entry on the 300 Log, check either "injury" or "all other illnesses.“ • 29 CFR 1904.12 was removed from the final rule.

  29. Peripheral nervous system disorders Carpal Tunnel Syndrome Raynaud’s/Vibration white finger syndrome Hernia Arthritis and related Sciatica Lumbago Rheumatism Bursitis/Synovitis Tendonitis Tenosynovitis Disc disorders of spine Myositis Eye strain Musculoskeletal system and connective tissue disorders, NEC General Signs & Symptoms Back pain, Hurt back Soreness, general pain, hurt (except back) Total Additions: 28 Values Additions to BLS Nature of Injury Values

  30. Fatality Reporting (1904.39) • Reporting fatalities and the hospitalization of three of more employees to OSHA within 8 hours has not changed. • The report must be made orally to the OSHA area office near the incident site or by using the toll free number, 1-800-321-6742 (OSHA).

  31. What OSHA resources are there? • OSHA’s recordkeeping website • http://www.osha.gov/recordkeeping/index.html • OSHA Recordkeeping forms • http://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf • How to determine OSHA recordability • http://www.osha.gov/recordkeeping/ppt1/RK1flowchart.html • OSHA Recordkeeping Handbook (OSHA 3245-01R, 2005) • http://www.osha.gov/recordkeeping/handbook/index.html

  32. DODI 6055.7 Mishap Classifications DODINST 6055.07 revision is nearing completion. Known/Proposed revisions are addressed.

  33. Mishap Reporting Contact Information OSH Specialist (USMC) Tactical Operations Naval Safety Center 757-444-3520 x7148 Safe_Code44@navy.mil WESS Help Desk 757-444-3520 x7048

  34. Mishap Classifications – Effective 1 Oct 09 • Classified by their degree of severity (DOD Memo) • Class A • $2 Million or more in material property damage; fatality or permanent total disability • Class B • $500K, but less than $2 Million in material property damage; permanent partial disability, or 3 or more persons hospitalized for inpatient care, beyond observation. • Class C • $50K or more, but less than $500K material property damage; work-related injury/illness causing 1 or more Lost Work Days • Other (New Class D - includes all other work-related cases.) • Medical Treatment beyond First Aid • Limited, Light or Restricted Duty or No Lost Work Time. • Proposed damage threshold greater than $20K First Aid cases may be reported via WESS, but will not appear on Log.

  35. Applicability to Military & Civilians • On-Duty and Off-Duty Military • Active duty, reserves, National Guard, cadets, midshipmen, ROTC, & foreign national military assigned to DOD components, on-base or off-base • Civil Service Employees • Navy and Marine Corps employees in an on-duty status – Includes DoN AF and NAF personnel and foreign nationals • DoN-Supervised Contractors • Contractor employees when DON provides the day-to-day supervision and a means to change the work environment (correct, control, eliminate or prevent hazards or mishaps). • Does not pertain to contractors at DON sites not under the direct supervision of DON

  36. DOD 6055.07 Draft • Proposed Changes: • Military and Civilian required to report IAW 29 CFR 1904 (OSHA Recordkeeping Requirements) • Establishes Minimum Data Elements required for certain types of mishaps – posted on DoD web-site • DSES reporting (WESS is auto-feeding data) • Sharing of military medical data with safety • Requires use of Civilian Compensation data to help identify reportable mishaps • Removing injury costs table from instruction • All services required to report mishaps involving members of other services against their mishaps

  37. Defense Safety Enterprise System (DSES) DSES is a centralized collection point for mishap data from the Military Services – The original goal was to feed data to DoD for further analysis across the Enterprise.

  38. DSES

  39. DSES DSES is now becoming an actual reporting venue. Rationale: Some DoD Agencies did not possess compliant reporting and recording on-line database capability.

  40. DSES However, the Military Services will continue to auto-feed data to DSES. Customers will not need to submit reports directly. On the other hand, DSES will likely be the source for back-feed of certain data to WESS.

  41. DSES

  42. 5102.1 Reportable Mishaps Explained Personnel Mission/Ops Fatalities, PTD/PPD, LWD (DART) cases, Medical Treatment, etc. Explosives/Weapons, Parachute, Diving, HRST, Combat Zone, etc. Property Damage Facility, Equipment, GMV, Tactical, etc. OPNAV 5102.1D / MCO P-5012.1B

  43. Reportable Mishaps • Class A, B, and C on-duty civilian and on/off-duty military injury/illness and property damage mishaps • Any other work-related illness or injury that involves medical treatment, beyond first aid or greater severity • Includes light or limited duty and job transfer or restricted work, partial work days due to injury (lost work time) • Special cases, e.g. Sharps, TB, Hearing Loss, Unconsciousness • Other reportable mishaps • Physical readiness or other training Class A mishaps • DOD-caused class A or B of dependent or guest of military • Conventional ordnance mishaps • On-duty diving cases, and those with hyperbaric treatment • All afloat groundings, collisions, floodings, and fires (exc. trash) • All GMV/GOV resulting in $5K or more prop damage, or injury Reference: 5102.1D Section 3004

  44. Reportable Mishaps – Cont’d • Other reportable mishaps - continued • Any mishap involving Helo Rope Suspension Technique, Cargo Air Drop, or Parachuting • Work-related mishap involving DON-supervised contractor, caused by DON evolution or operation. Contractors are still responsible for reporting their mishaps to OSHA. • Medically diagnosed work-related injury or illness (CTD) with or without lost work time or further medical treatment • Work-related Significant Threshold Shift in Hearing • Work-related Needle Stick or Sharps mishap • Work-related TB infection • Any case requiring a civilian employee to be removed from work under the requirements of an OSH standard • Combat Zone mishaps • Mishaps are not the result of direct enemy action • Shorter version of required report

  45. Combat Zone Report • COMBAT ZONE REPORTING • Change 1 to 5102.1 • New Combat Zone Report – Figure 5-7 • WESS Reprogrammed for Combat Zone Reporting

  46. Changes to the CZR • LIMDIST • Combat Zone Reports are Assigned to COMMARCENT (USMC) • INFO Administrative Chain of Command • LIST OPCON Chain of Command • Duty Status • Motor/Tactical Vehicle & Weapons Info • 24 Hour Profile • Causal Factors Reference: 5102.1, Figure 5-7

  47. Combat Zone Report

  48. Consolidated Reportable Mishaps Personnel Mission/Ops Fatalities, PTD/PPD, LWD (DART) cases, Medical Treatment, etc. Explosives/Weapons, Parachute, Diving, HRST, Combat Zone, etc. Property Damage Facility, Equipment, GMV, Tactical, etc. OPNAV 5102.1D / MCO P-5012.1B

  49. Mishap Investigations • The following mishaps are to be investigated by a Safety Investigation Board (SIB) and reported via naval message in the Safety Investigation Report (SIREP)/WESS within 30 days. • Class A • Fatality • Permanent Total Disability • Property Damage greater than $ 2 million dollars • All Class A operational mishaps. • Other • Fatality was result of medical event commencing within 1 hour of PFA / PFT / PRT or remedial PT required by command • Training-related fatalities • All Class A, B, or C Explosives/Live Fire mishaps.

  50. Mishap Investigations • Reporting • Safety Investigation Report (SIREP) - joint format • Parts A (general) and B (investigation board) • Sent by naval message • Sent electronically using WESS or WESS-DS • WESS - uses same data elements as the SIREP • WESS is the preferred method of reporting • Unit must enter info from SIREP into WESS • Disconnected version for those without reliable internet, must have at least e-mail access • Reports must be submitted within 30 days All recordable mishaps are entered into WESS. In effect, all recordable events are now considered “reportable” mishaps.

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