Recordkeeping

Q:  How do you count the lost work/restricted days on the OSHA 300 log?

A:  You'll need to count all the days away from work starting the day after the employee was injured (even if it’s a weekend, or an employee is not scheduled). When the employee returns for restricted/light duty, count those days until they returned to full duty.

Recordkeeping

Q:  One of our employees slipped on ice and hurt their neck.  They were off for more than a year.  Is there a limit to days that need to be recorded?

A:  OSHA states the days away from work are capped at 180. This is noted in the following regulation:

·     1904.7(b)(3)(vii) Is there a limit to the number of days away from work I must count? Yes, you may "cap" the total days away at 180 calendar days. You are not required to keep track of the number of calendar days away from work if the injury or illness resulted in more than 180 calendar days away from work and/or days of job transfer or restriction. In such a case, entering 180 in the total days away column will be considered adequate.

Recordkeeping

Q: When filling out the 300 logs what do you do for an injury that occurred in one year, but that employee is still injured and he still is unable to return to work for the next calendar year?

A: The answer is found under 1904.7(b)(3)(ix).  You only record the injury or illness once.  You must enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap.

Recordkeeping

Q. An employee was instructed to keep a wound finger “clean and dry.”  Would this be considered light duty?

A. As long as the employee can perform his normal job duties, this would not be considered light duty.

Recordkeeping

Q: An employee was on light duty in 2011.  Do I have to carry this over to my 2012 log?

A: No, all days should be recorded on the 2011 log.

Drug Testing

Q: Does OSHA require or regulate employee drug testing programs?

A: No, although many states and insurance companies will require a testing program for certain tasks such as operating commercial vehicles.  For safety and health, it is always a good idea to make sure employees are drug and alcohol free while at work.  Workers compensation carriers should be able to provide more information that will specifically apply to your business.

Recordkeeping

Q:  Are there any exceptions for us with recordkeeping since we only have 9 employees?

A:  As long as you have fewer than 10 employees throughout the year you would be exempt.

http://www.osha.gov/recordkeeping/index.html

 

Arc Flash

Q: Is it acceptable to use alternative personal protective protection when applying ‘the table method’ to protect employees from arc flash hazards?

A: Unless you can prove through arc flash analysis data that the PPE will provide sufficient protection, it is not recommended.

Arc Flash

Q: Where can I find reference material for arc flash?

A: The two best sources are the NFPA 70E (available for a fee at www.NFPA.org) and OSHA 1910 Subpart S standard (available for no cost at www.osha.gov).

Recordkeeping

Q: An employee was injured in 2011 and will be away from work for >180 days.  Do I have to put this on my 2012 log in addition to 2011?

A: The injury should only be counted in the year that the injury occurred.  All 180 days should be counted in 2011.

Fall Protection at Loading Docks

Q:  We would like to know if you have the OSHA requirements necessary for our loading dock area for a rail or barrier. We are in the midst of having our chains replaced with a more secure barrier. Our loading dock is about 5’ off the ground. Any information would be great.

A:  You’ll want to make sure the new barriers that you install meet the following criteria:

• Top rail at 42 inches in height and capable of withstanding 200 lbs of outward and downward force.  
• Midrail at 21 inches in height.

I’ve seen some facilities use 2x4 boards for these barriers.  They install brackets on the inside of the door that hold the boards.  They are then able to lift the boards out of brackets with ease in order to use the dock.  This seems to be a sturdy solution for a removable barrier at the dock.  This is just a suggestion as I’m not sure if this would work for your application. 

Battery Charging PPE

Q: We have forklifts and power floor sweepers that operate off of batteries.  We have an eyewash station in the charging/changing area, but what types of PPE should we require?   
A: Goggles, face shields, aprons, and rubber gloves need to be worn while handling the batteries.  Refer to the MSDS of the battery acid to determine the type of rubber gloves/aprons that need to be worn.

Scissor Lift Training

Q:  Does OSHA have specific training requirements for scissor lifts?

A:  Since scissor lifts are covered under OSHA’s scaffolding trainings there are no specific training requirements.  However, under the general duty clause it would be the employer’s responsibility to ensure all operators are competent and authorized to operate the lift.  

Contact us for more information on OSHA training.