CONN-OSHA Answers Your Safety Questions: August 2022
Welcome to our monthly column featuring CONN-OSHA experts answering some of the most commonly asked safety questions from CBIA member companies.
Most of the responses from Catherine Zinsser, a CONN-OSHA occupational safety training specialist, will be on recordkeeping since that is the focus of most questions she fields.
But if you’d like to ask her a question on another topic, please email CBIA’s Phillip Montgomery.
He will treat all questions confidentially and never share any identifying company information with CONN-OSHA or anyone else.
Q: If a healthcare professional determines an employee is fully able to perform all of his or her routine job functions, but the employee experiences minor musculoskeletal discomfort and the employer assigns a work restriction to the injured employee, does the employer have to record a work-related injury and illness?
A: As set out in Chapter 2, I., F. of the Recordkeeping Policies and Procedures Manual (CPL 2-0.131) a case would not be recorded under section 1904.7(b)(4) if 1) the employee experiences minor musculoskeletal discomfort, and 2) a health care professional determines that the employee is fully able to perform all of his or her routine job functions, and 3) the employer assigns a work restriction to that employee for the purpose of preventing a more serious condition from developing.
If a case is or becomes recordable under any other general recording criteria contained in section 1904.7, such as medical treatment beyond first aid, a case involving minor musculoskeletal discomfort would be recordable.
Q: If I had one work-related accident but two employees were injured, does this get recorded as one or two cases on the OSHA Log?
A: OSHA’s Recordkeeping system tracks work-related recordable injuries and illnesses.
If both injuries meet the general recording criteria of Section 1904.7 or the application to specific criteria of Section 1904.8 through Section 1904.11, both cases should be recorded on the Log as two separate cases.
Q: Do I have to give my employees and their representatives access to the OSHA injury and illness records?
A: Yes, your employees, former employees, their personal representatives, and their authorized employee representatives have the right to access the OSHA 300 Log Form and the OSHA 300-A Summary Form.
The employer must give the requester a copy of the OSHA 300 Form and the OSHA 300-A Form by the end of the next business day.
In addition, employees and their representatives have the right to access the OSHA 301 Incident Form with some limitations, in section 1904.35(b)(2)(v)(B) of the recordkeeping regulation.
For more information, contact CBIA’s Phillip Montgomery (860.244.1982).
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