Safety Policy and Procedure
Policy Number: 018 Authorized By: The Cianbro Companies
Alan Burton
Title: OSHA Recordable Cases Effective Date: 03/01/87 Page 1 of 9
1 Status
1.1 Update of existing policy, effective 03/07/11.
2 Purpose
2.1 To accurately report OSHA recordability cases.
3 Applicability
3.1 This policy applies to all subsidiary companies and departments of The Cianbro Companies.
3.2 All organizations are required to comply with the provisions of this policy and procedure. Any
deviation, unless spelled out specifically in the policy, requires the permission of the Corporate Safety Officer or designee.
4 Definitions
4.1 MSD: Musculoskeletal Disorders.
4.2 OSHA recordable, lost time: Days away from work.
4.3 OSHA recordable, non-lost time: Medical treatment beyond first aid.
4.4 OSHA recordable, restricted time: Restricted Work Activity (RWA).
4.5 PLHCP: A Physician or other Licensed Health Care Professional is an individual whose legally
permitted scope of practice allows him or her to independently perform, or to be delegated the responsibility to perform, the activities described by this regulation. (In most states, from a practical standpoint that is a registered nurse, physician’s assistant, nurse practitioner or physician (DO or MD).
4.6 Work Environment: The establishment and other locations where one or more team members
are working or present as a condition of employment. It includes not only physical locations, but also the equipment or materials used by team members during the course of their work.
5 Policy
5.1 Cianbro will maintain and retain accurate records as set forth by the Occupational Safety and
Health Act of 1970 and Part 1904.
6 Responsibilities
6.1 The Corporate Safety Officer or designee is responsible for final decision on how to report on
the OSHA 300 log.
6.2 The top Cianbro manager on the job site is responsible for the implementation of this policy on
7 OSHA Recordable Cases Index
7.1 OSHA ... 2
7.2 Recordability and Recordkeeping and Posting ... 2
7.3 Investigations ... 3
7.4 Injury Management... 3
7.5 OSHA Recordability vs. Workers Compensation ... 3
7.6 Determining Work Relatedness ... 4
7.7 Recordability... 5
7.8 Administration... 7
9 Related Documents... 9
7.1 OSHA
7.1.1 The Occupational Safety and Health Act of 1970 require Cianbro to record and report
work related fatalities, injuries and illnesses. These records determine Cianbro’s recordable incident rate (RIR) and when compared to other contractors across the country are an indication of Cianbro’s “safety record”.
7.1.2 OSHA reporting requirements determine frequency and severity to allow individual
team members to focus their efforts on improvement. It is important that we present an accurate picture of our ability to work safely.
7.1.3 The recordable incident rate is determined by multiplying the number of recordable
injuries by 200,000 (one hundred workers for one year) then dividing by the actual number of work hours. The calculation emphasizes both large and small numbers of team members. Cianbro’s incident rates are based on the record of Cianbro team members and others under direct Cianbro supervision such as temps. Do not include injuries or work hours of subcontractor team members that are under their own supervision in these records or calculations.
N (recordable cases) x 200,000 YTD work hours
7.2 Recordability and Recordkeeping and Posting
7.2.1 Generally, work-related injuries and illness that require treatment beyond first aid are
considered recordable.
7.2.2 New recordable injuries must be entered on OSHA Form 300-Log of Work-Related
Injuries and Illnesses. Disability Management in the corporate office in Pittsfield, Maine will do a bi-annual review with each project to keep the corporate log updated. The official OSHA 300 for all projects is the corporate log; because most of our project sites are over within a 12 to 36 months period. This log must be updated and maintained for five years following the year that it covers.
7.2.3 OSHA Form 300A- Summary of Work-Related Injuries and Illnesses must be posted
from February 1 to April 30 for the year proceeding the posting period.
7.2.4 Recordability may depend on many factors including the severity of the event or
exposure, treatment required, medications administered, return-to-work/injury management plan, and Cianbro’s relationship with the injured team member and treatment provider. Pre-planning and relationship building are critical components of injury management and can substantially impact our incident rates.
7.3 Investigations
7.3.1 The Cianbro First Report of Incident (form DM001) is to be used for initial investigation
and reporting of all injuries and near misses. This form and any supporting materials
must be completed and forwarded to [email protected].
7.3.2 It may be difficult to determine whether an injury or illness is work-related. It is
extremely important that all injuries and near misses, regardless of the apparent severity, be thoroughly investigated to discover and explore all of the facts surrounding the incident. Investigations should include identifying the mechanism of injury, the duration and type of activity being performed by the injured team member, taking any witness statements, and any other relevant details. All incidents or injuries must be taken seriously. Incidents or injuries that appear to be minor at the start sometimes end up becoming an OSHA recordable. We can minimize the number of recordable injuries by ensuring proper planning and ensuring that all incidents are investigated for root cause and that appropriate treatment is provided promptly. See Safety Policy and Procedures: #023 Incident Investigation and #038 Injury Management and First Report of Incident (form DM001).
7.3.3 First reports of injury and any accompanying investigation will be reviewed pursuant to
Cianbro protocol for recordability and work-relatedness using the causation checklist based on ACOEM standards.
7.4 Injury Management
7.4.1 The project safety specialist or designee must accompany the injured team member to
the designated clinic or doctor’s office. At the time of treatment the safety specialist should discuss with the treatment provider the nature and severity of the injury, recommended treatment, work modifications (if any) and follow-up care. The safety
specialist will explain Cianbro’s modified work programto ensure the provider thatwe
will accommodate any work modifications given to the team member. This is an
effective tool for the prevention of recordable and lost time incidents.It is important that
we demonstrate to the injured team member and the doctor how important that team
member is to us. The extra time spent with our people andmedicalproviders will
demonstrate our concern and care; develop trustandcreatea spirit of cooperation that
will benefit the entire Cianbro team.
7.4.2 Upon return to the jobsite, the work modifications agreement form must be reviewed
and signed by the team member, safety specialist and supervisor to ensure that the work modifications are understood and will not be exceeded.
7.4.3 In an effort to provide quality medical care while also reducing recordability due to
unnecessary or excessive medical intervention, treatment protocols will be presented to our network of occupational clinics. Whenever possible, the safety specialist should ask the medical provider to adhere to these protocols. The Cianbro medical director will provide support and guidance with this process.
7.5 OSHA Recordability vs. Workers Compensation
7.5.1 Recordable injury and illness cases do not in any way determine compensability under
workers’ compensation. Sometimes there is little relationship between the two. Each case must be investigated and evaluated on its own facts and merits. Transfer to another job in order to accommodate modified work capacity is not by itself recordable. Likewise, absence from work as a decision by the team member may not make a case recordable or compensable. If you have questions regarding recordability, please
7.6 Determining Work Relatedness
7.6.1 An injury or illness is work-related if an event or exposure in the work environment
either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness.
7.6.2 Cianbro requires a physician’s diagnosis for work related illness. Because of the long
term implications all illness cases will be reviewed by OMC.
7.6.3 A pre-existing injury or illness is significantly aggravated when an event or exposure in
the work environment results in any of the following (which otherwise would not have occurred)
Death
Loss of consciousness
Days away, days restricted, or job transfer Medical treatment beyond first aid
Significant injury or illness diagnosed by a PLHCP
7.6.4 Work related cases involving cancer, chronic irreversible disease, a fracture or cracked
bone, or a punctured eardrum must always be recorded at the time of the diagnosis by a PLHCP, even if medical treatment, days away or work restrictions are not
recommended.
7.6.5 Work relatedness is presumed for injuries and illnesses resulting from events or
exposures occurring in the work environment.
7.6.6 Exceptions – the following are NOT considered work-related
At the time of the injury or illness, the team member was present in the work environment as a member of the general public rather than as a team member. The injury or illness involved signs or symptoms that surface at work, but result solely from a non-work-related event or exposure that occurs outside the work environment.
The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball or baseball.
The injury or illness is solely the result of a team member eating, drinking, or preparing food or drink for personal consumption (whether purchased on the employer’s premises or brought in). For example, if the team member is injured by choking on a sandwich while in the employer’s establishment, the case would not be considered work-related.
The injury or illness is solely the result of a team member doing personal tasks (unrelated to their employment) at the establishment outside of the team member’s assigned working hours.
The injury or illness is solely the result of personal grooming, self-medication for a non-work-related condition, or is intentionally self-inflicted.
The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the team member is commuting to or from work.
The illness is the common cold or flu (Note: contagious diseases such as
tuberculosis, brucellosis, hepatitis A, or plague are considered work-related if the team member is infected at work).
The illness is a mental illness. Mental illness will not be considered work-related unless the team member voluntarily provides the employer with an opinion from a physician or other licensed health care professional (PLHCP) with appropriate training and experience stating that the team member has a mental illness that is work-related. PLHCP in this case would be a psychiatrist, psychologist or
7.6.7 Travel Status
An injury or illness that occurs while a team member is on travel status is work-related if it occurred while the team member was engaged in the work activities in the interest of the employer.
Hotel is considered home away from home (not recordable). Detour for personal reasons is not work-related (not recordable).
Activities that are considered “in the interest of the employer” would include travel to and from customer contacts, conducting job tasks, and entertaining or being entertained to transact, discuss or promote business (with the entertainment being at the direction of the employer).
7.6.8 Work at Home
Injuries and illnesses that occur while an team member is working at home are work-related if they occur while the team member is performing work for pay or compensation in the home and they are directly related to the performance of work rather than the general home environment.
7.7 Recordability
7.7.1 New Case
A case is new if:
The team member has not previously experienced a recordable injury or illness of the same type that affects the same part of the body; or
The team member previously experienced a recordable injury or illness of the same type that affects the same part of the body, but had recovered completely and an event caused the signs and symptoms to reappear.
7.7.2 Recording Fatalities
Work-related fatalities must be recorded by checking the box for cases resulting in deaths.
Work-related fatalities must also be reported to OSHA within 8 hours.
7.7.3 Days Away Cases
Record if the case involves one or more calendar days the team member was unable to work (include weekend days, holidays, vacation days, etc.)
Do not include the day of the injury/illness.
Cap day count at 180 days away and/or days restricted (total of both not to exceed 180).
May stop day count if the team member leaves the company for a reason unrelated to the injury or illness.
If a medical opinion exists, the employer must follow that opinion.
7.7.4 Restricted Work Cases
Record if the case involves one or more days of restricted work or job transfer. Check the box for restricted/transfer cases and count the number of days. Do not include the day of the injury or illness.
Restricted work activity occurs when:
A team member is kept from performing one or more routine functions (work activities the team member regularly performs at least once per week) of his/her job.
A team member is kept from working a full workday. A PLHCP recommends either of the above.
7.7.6 Medical Treatment
Medical treatment is the management and care of a patient to combat disease or disorder. Medical treatment does not include:
Visits to a PLHCP solely for observation or counseling.
Diagnostic procedures such as x-rays, blood tests and medications used for diagnostic purposes (such as eye drops to dilate the pupils).
First aid.
There are 14 treatments that are considered first aid. Any treatment beyond those 14 items is considered medical treatment, regardless of who provides the care. They are: Using nonprescription medication at nonprescription strength (prescription
medications or prescription strength of Over-the-Counter medications recommended by a PLHCP are considered medical treatment).
Tetanus immunizations (other immunizations such as Hepatitis B vaccine or rabies vaccine are medical treatment).
Cleaning, flushing, or soaking surface wounds on the surface of the skin. Wound coverings, butterfly bandages, Steri-strips (wound closure glue is
considered medical treatment). Hot or cold therapy (any amount).
Non-rigid means of support such as ace bandages, elbow and wrist wraps, and back belts (note that devices with rigid stays such as wrist splints would be considered medical treatment).
Temporary immobilization device used to transport accident victims (splints, slings, neck collars, back boards, etc).
Drilling of fingernail or toenail to relieve pressure, or draining fluid from a blister.
Eye patches.
Removing foreign bodies from the eye using only irrigation or a cotton swab. Removing splinters or foreign material from areas other than the eye by irrigation,
tweezers, cotton swabs or other simple means.
Finger guards.
Massages (Note that all physical therapy or chiropractic treatments are considered medical treatment for recordkeeping purposes).
Drinking fluids for relief of heat stress.
7.7.7 Bloodborne Pathogens
Record all work-related needlesticks and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material (includes human bodily fluids, tissues and organs. Record splashes or other exposures to blood or other potentially infectious material if it results in diagnosis of a bloodborne disease or meets the general recording criteria.
7.7.8 Medical Removal
If a team member is medically removed under the medical surveillance requirements of an OSHA standard, you must record the case.
The case is recorded as either one involving days away from work or days of restricted work activity.
If the case involves voluntary removal below the removal levels required by the standard, the case need not be recorded.
7.7.9 Hearing Loss
A case must be recorded when a confirmed standard threshold shift meets two criteria. First, you must have a 10 db shift in one or both ears from the baseline (measured at 2000, 3000, and 4000 hz). Second, the shift must make the team members hearing greater than 25 db from audiometric zero. If both criteria are satisfied on one or both ears, then the case is recordable.
7.7.10 Musculoskeletal Disorders (MSD)
7.8 Administration 7.8.1 Forms
OSHA Form 300 – Log of Work-Related Injuries and Illnesses OSHA Form 300A – Summary of Work-Related Injuries and Illnesses OSHA Form 301 – Injury and Illness Incident Report - Recordable cases must be entered on the OSHA 300 within 7 calendar days of receiving information that a recordable case occurred. Do not enter the name of an team member on the OSHA Form 300 for “privacy concern” cases. Enter “privacy case” in the name column. Keep a separate confidential list of the case numbers and team member names of “privacy concern” cases. Make sure to fill out the form completely and accurately including the description in column F (Include the illness or injury, parts of body affected, and object/substance that directly injured or made person ill). If you are unsure of how to fill out the log, contact the corporate office in Pittsfield, Maine and ask for the Disability Management experts.
7.8.2 Privacy Protection - Privacy concern cases are:
An injury or illness to an intimate body part or reproductive system. An injury or illness resulting from sexual assault.
Mental illness.
HIV infection, hepatitis, tuberculosis.
Needlestick and sharps injuries that are contaminated with another person’s blood or other potentially infectious material.
Team member voluntarily requests to keep name off for other illness cases. Names must be removed when sharing information with people not authorized by
the rule. Exceptions are when that information is needed to process workers compensation claims, an internal or external consultant performing an evaluation of the safety and health program and a public health authority or law enforcement agency.
7.8.3 Multiple Sites
This section requires that we keep a separate OSHA Form 300 for each job site that is expected to be in operation for more than a year. One OSHA Form 300 may be kept for all short-term jobs. Either way, each team member must be linked with one particular job.
7.8.4 Covered Team Members
The following must be included on our OSHA 300 log:
All team members on the payroll, including part-time and seasonal.
Employees not on our payroll, who are supervised on a day-to-day basis (Temp services’ employees working for us).
Exclude self-employed and partners.
Temporary help agencies should not record the cases experienced by temporary workers who are supervised by Cianbro.
7.8.5 Posting the Annual Summary
New guidelines for posting the OSHA 300A Summary: A company executive must certify the summary. That person must be:
An owner of the company. An officer of the corporation.
The highest ranking company official working at the establishment, or His or her supervisor.
The summary can not be certified by the safety specialist
Must post for 3 month period, from February 1 to April 30 each year for the year proceeding the posting period and then maintain the summary on file.
7.8.6 Retention and Updating
Retain forms for 5 years following the year that they cover (corporate log after job completion).
Update the OSHA form 300 during that period.
Do not need to update the OSHA Form 300A or OISHA Form 301.
7.8.7 Team member Involvement
Cianbro must provide limited access to injury and illness records to team members, former team members and their personal and authoritative representatives.
Cianbro must provide one free copy of OSHA Form 300 by end of next business day.
Cianbro must provide one free copy of OSHA Form 301 to team member, former team member or personal representative by the end of the next business day. Cianbro must provide copies of OSHA Form 301 to authorized representative
within 7 calendar days. Provide only “information about the case” section of the form.
7.8.8 Prohibition Against Discrimination
OSHA prohibits the employer from discriminating against a team member for reporting a work-related fatality, injury or illness.
OSHA also protects the team member who files a safety and health complaint, asks for access to the part 1904 records, or otherwise exercises any rights afforded by OSHA.
7.8.9 Fatality/Catastrophe Reporting
Report verbally within 8 hours to an OSHA area office.
Work-related fatality.
Incident involving 3 or more in-patient hospitalizations. Fatal heart attacks at work.
Do not report:
Highway or public street motor vehicle accidents (outside of a construction work zone).
Commercial airplane, train, subway, or bus accidents. If more than 30 days post-incident.
*Note: The above are still recordable on the 300 log if they meet the other criteria. 7.8.10 Providing Records to Government Officials
Must provide copies of the records within 4 business hours.
Use the business hours of the establishment where the records are located. 7.8.11 Annual OSHA Survey
Employer must fill out the annual OSHA random survey if requested. OSHA 300 Form information does not need to be sent to any agency unless
requested. 7.8.12 Annual BLS Survey
Employer must fill out the annual random survey from BLS if requested. 7.8.13 Resources
OSHA website – www.osha.gov
Forms may be downloaded from the web-site along with the standard and other recordkeeping information.
OSHA Regional Recordkeeping Coordinator Region 1 – Shirley Boulware – (617)565-9856
8 Budget / Approval Process
8.1 It is the responsibility of each jobsite to procure and provide all materials and PPE required and
provide necessary training.
9 Related Documents
9.1 References
023 Incident Investigation Safety Policy and Procedure 038 Injury Management Safety Policy and Procedure
9.2 Documents available on Cianbro.net>Resources
OSHA 300A Summary of WR Injuries & Illnesses DM004
First Report of Incident DM001