Q & A: The 4 D's of Documentation
Question: “Can you review the four D's of documentation?”
Answer: “If you Didn’t Document it, you Didn’t Do it.”
Words to live by, sure, but that may not be super helpful here, so here’s information straight from the OSHA’s inspection field manual…
a. The recordkeeping regulation at §1904.40(a) states that once a request is made, an employer must provide copies of the required recordkeeping records within four (4) business hours.
b. Although the employer has four business hours to provide injury and illness records, the compliance officer is not required to wait until the records are provided before beginning the walkaround portion of the inspection. As soon as the opening conference is completed, the compliance officer is to begin the walkaround portion of the inspection. NOTE: 29 CFR Part 1904 has new requirements for reporting work-related fatalities, hospitalizations, amputations or losses of an eye. The new rule, which also updates the list of employers partially exempt from OSHA record-keeping requirements, went into effect on January 1, 2015, for workplaces under federal OSHA jurisdiction. (See 79 FR 56129, Occupational Injury and Illness Recording and Reporting Requirements – NAICS Update and Reporting Revisions, September 18, 2014.)
Review of Records. A. Injury and Illness Records.
1. Collection of Data.
a. At the start of each inspection, the CSHO shall review the employer’s injury and illness records for five prior calendar years, record the information on a copy of the OSHA-300 screen, and enter the employer’s data using the OIS Application 3-12 on the NCR (micro). This shall be done for all general industry, construction, maritime, and agriculture inspections and investigations.
b. CSHOs shall use these data to calculate the Days Away, Restricted, or Transferred (DART) rate and to observe trends, potential hazards, types of operations and work-related injuries.
c. If recordkeeping deficiencies or unsound employer safety incentive policies are discovered, the CSHO and the Area Director (or designee) may request assistance from the Regional Recordkeeping Coordinator. See Richard E. Fairfax Memo, Employer Safety Incentive and Disincentive Policies and Practices (March 12, 2013) at: http://www.osha.gov/as/opa/whistleblowermemo.html.
2. Information to be Obtained.
a. CSHOs shall request copies of the OSHA-300 Logs, the total hours worked and the average number of employees for each year, and a roster of current employees.
b. If CSHOs have questions regarding a specific case on the log, they shall request the OSHA-301s or equivalent form for that case.
c. CSHOs shall check if the establishment has an on-site medical facility and/or the location of the nearest emergency room where employees may be treated. NOTE: The total hours worked and the average number of employees for each year can be found on the OSHA-300A for all past years.
B. Recording Criteria. Employers must record new work-related injuries and illnesses that meet one or more of the general recording criteria or meet the recording criteria for specific types of conditions.
- Days Away from Work;
- Restricted Work;
- Transfer to another job;
- Medical treatment beyond first aid;
- Loss of consciousness;
- Diagnosis of a significant injury or illness; or
- Meet the recording criteria for Specific Cases noted in §1904.8 through §1904.11.
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