OSHA Recordkeeping Handbook - denix

§1904.29have also been designed to fit on the same-sizepaper as the OSHA 300 Log. For those employerswho use computerized systems (where handwritingspace is not as important) equivalent computer-generatedforms can be printed out on 81/2 x 11 sheets ofpaper if the printed copies are legible and are asreadable as the OSHA forms....Defining Lost WorkdaysOSHA proposed to eliminate the term “lost workdays,”by replacing it with “days away from work”(61 FR 4033). The OSHA recordkeeping system hashistorically defined lost workdays as including bothdays away from work and days of restricted workactivity, and the Recordkeeping Guidelines discussedhow to properly record lost workday cases with daysaway from work and lost workday cases with days ofrestricted work activity (Ex. 2, p. 47, 48). However,many use the term “lost workday” in a manner thatis synonymous with “day away from work,” and theterm has been used inconsistently for many years....In the final rule, OSHA has eliminated the term“lost workdays” on the forms and in the regulatorytext. The use of the term has been confusing formany years because many people equated the terms“lost workday” with “days away from work” andfailed to recognize that the former OSHA term includedrestricted days. OSHA finds that deleting this termfrom the final rule and the forms will improve clarityand the consistency of the data.The 300 Log has four check boxes to be used toclassify the case: death, day(s) away from work,day(s) of restricted work or job transfer; and casemeeting other recording criteria. The employer mustcheck the single box that reflects the most severeoutcome associated with a given injury or illness.Thus, for an injury or illness where the injured workerfirst stayed home to recuperate and then wasassigned to restricted work for several days, theemployer is required only to check the box for daysaway from work (column I). For a case with only jobtransfer or restriction, the employer must check thebox for days of restricted work or job transfer(Column H). However, the final Log still allowsemployers to calculate the incidence rate formerlyreferred to as a “lost workday injury and illness rate”despite the fact that it separates the data formerlycaptured under this heading into two separate categories.Because the OSHA Form 300 has separatecheck boxes for days away from work cases andcases where the employee remained at work but wastemporarily transferred to another job or assigned torestricted duty, it is easy to add the totals from thesetwo columns together to obtain a single total to usein calculating an injury and illness incidence rate fortotal days away from work and restricted work cases.Counting Days of Restricted Work or Job TransferAlthough the final rule does not use the term “lostworkday” (which formerly applied both to days awayfrom work and days of restricted or transferredwork), the rule continues OSHA’s longstanding practiceof requiring employers to keep track of the numberof days on which an employee is placed onrestricted work or is on job transfer because of aninjury or illness....In the final rule, OSHA has decided to requireemployers to record the number of days of restrictionor transfer on the OSHA 300 Log. From the commentsreceived, and based on OSHA’s own experience,the Agency finds that counts of restricted daysare a useful and needed measure of injury and illnessseverity. OSHA’s decision to require the recordingof restricted and transferred work cases on theLog was also influenced by the trend toward restrictedwork and away from days away from work....The final rule thus carries forward OSHA’s longstandingrequirement for employers to count andrecord the number of restricted days on the OSHALog. On the Log, restricted work counts are separatedfrom days away from work counts, and the term“lost workday” is no longer used. OSHA believesthat the burden on employers of counting these dayswill be reduced somewhat by the simplified definitionof restricted work, the counting of calendar daysrather than work days, capping of the counts at 180days, and allowing the employer to stop countingrestricted days when the employees job has beenpermanently modified to eliminate the routine jobfunctions being restricted (see the PreambleDiscussion for 1904.7 General Recording Criteria).Separate 300 Log Data on Occupational Injury andOccupational Illness...After a thorough review of the comments in therecord...OSHA has concluded that the proposedapproach, which would have eliminated, for recordingpurposes, the distinction between work-relatedinjuries and illnesses, is not workable in the final rule.The Agency finds that there is a continuing need forseparately identifiable information on occupationalillnesses and injuries, as well as on certain specificcategories of occupational illnesses. The publishedBLS statistics have included separate estimates of therate and number of occupational injuries and illnessesfor many years, as well as the rate and number of112OSHA RECORDKEEPINGHANDBOOK