OSHA recordkeeping rules
You are working for a safety consulting firm that contracts compliance services to small businesses. Your mission is to help ABC Roofing Company comply with Part 1904 OSHA recordkeeping rules for the year ending 2018. The company office is located at 1234 Park Ave, Houma, LA 70360. There are 100 full time workers and the company has a total of 200,000 work hours logged for the calendar year ending 12/31/2018. The NAICS code for this company is 23816 Roofing Contractors. You will need this to look up the industry TRIR and DART rates. The company has provided a listing of all incidents that have occurred during 2018 but is not sure which should be recorded on the OSHA logs. All incidents occurred in OSHA jurisdiction for recordkeeping purposes. You duty is to comply with the 1904 recordkeeping rules and complete the OSHA 300 and 300A summary accurately for the client.
In addition, Mr. Tim Smith, ABC Construction Company President, has asked you to compare ABC Roofing’s OSHA incident rates to the industry average for Total Recordable Rates and Cases with days away from work, job restriction or transfer (DART Rate) using the latest available BLS data. For purposes of this assignment, use the following link to the bureau of Labor Statistics for injury and illness rates published as of 2017. https://www.bls.gov/web/osh/summ1_00.htm
Look up NAICS code in second column for roofing contractors and locate the total recordable cases column and Total column for days away from work, rob restriction or transfer. This is what you will benchmark ABC Roofing’s experience to as described herein.
Note the incident rate represent the number of injuries and illnesses per 100 full-time workers and were calculated as: (N/EH) x 200,000, where
N = number of injuries and illnesses
EH = total hours worked by all employees during the calendar year
200,000 = base for 100 equivalent full-time workers (working 40 hours per week, 50 weeks per year)
In your memo you must specifically include a table and or chart of Total Recordable Incident Rates and Days Away Restricted and Transfer (DART) rates and compare it to benchmark information. From this you should clearly be able to conclude it the company experience is the same, better or worse than industry. You may need to do some research to learn how to calculate incident rates. Refer to Incident Rate Calculator and Comparison Tool handout in Moodle for additional guidance. https://safetymanagementgroup.com/resources/incident-rate-calculator/
You will ultimately produce the OSHA 300 log, 300A Summary and create a memo using MS WORD for Mr. Smith that explains OSHA record posting requirements and document retention rules for the 300 log, 300 A summary and 301 Incident report including time frame if any that you have to keep these records.
Here are the cases that occurred. You must determine if the meet the recordability requirements of Part 1904 and correctly record these on the OSHA 300 and 300A logs. Refer to OSHA website for additional guidance and letters of interpretation to accurate determine recordability of the following 10 incidents.
1. 1/21/18– Tom Jones, carpenter hurt his back lifting plywood in the shop and was admitted to ER. The doctor prescribed pain killers. He could not return to work for 20 days and the doctor then placed him on restricted duty for 20 days.
2. 2/14/18 – James Jones, a receiving clerk was cutting plastic banding straps on a bundle of 2 by 4 with knife in shop. Mr. Jones was not wearing the proper gloves which resulted in a cut on the left top of hand. The safety coordinator treated the cut with butterfly band aid. Mr. Jones returned to normal duty without future incident.
Note: The determination of medical treatment and first aid is always difficult to determine. For this case, refer to OSHA Interpretations to verify your answer here.
3. 3/8/18 – Susie Smith, Office manager was making bank deposit in her personal vehicle for the company and was involved in car accident in route to the bank and broke her neck. She spent 14 days in the hospital and then could not return to work for another 260 days.
4. 4/20/18 –Billy Bob, construction superintend was walking down a set of stairs at the shop and slipped on the stairs and twisted his ankle. The doctor checked him out and x-rayed his ankle. He was then released to go back to work but doctor prescribed that he wear a ridged boot to support his ankle for 30 days. Billy Bob decided not to wear the boot and resumed normal duties.
5. 5/18/18 – Thomas O’Malley was working at jobsite on the roof and slipped and fell about 10 feet to the ground landing on his back. He was hospitalized with severe back pain for 3 days and then underwent extensive pain management, rehab but never returned to work. He obtained a lawyer and the case has been making it way through the workers compensation courts.
6. 6/10/18 – Peter Pan, is a helper and was on a jobsite. He was cutting some wood with a skill saw and got wood dust in his eye. The supervisor flushed his eye with eye wash solutions but his eye was severely irritated. So supervisor took his to doctor’s office. The Company Doctor had to remove the wood dust from his eye using irrigation, performed an x ray to ensure all trash was removed from the eye and Peter Pan was able to returned to work the same day.
Mike Mars, a rig mechanic, slipped and fell on a wet floor while walking through the galley of Rig 2260 and sprained his right ankle in the fall. He was seen by the doctor who prescribed an anti-inflammatory. The doctor placed him on restricted duty for 10 days but Mike decided he could return to full duty, and he did so without any problems. While this is recordable how do you count the days. Be accurate on the OSHA log.
7. 7/10/2018 – Mike Nicholls, was a new hire on the job and during his first day on the job he got over-heated had to be taken to hospital for heat stress. He was treated with and fluid IV and doctor put him on restriction because of the heat stress incident for 10 days. The employee was embarrassed and quite the same day and never returned to work.
8. 8/4/18 -Paul Brown was climbing down an extension ladder on the jobsite and missed a step. He fell and landed on his right side and was seriously injured. An ambulance was called to take him to the hospital. He was treated for a broken hip, prescribed pain meds and sent home for 180 days. He never returned to work.
9. 9/25/18 – Marcus Brown, was a laborer and was on the jobsite helping a deliver driver unload roofing shingles. He climbed up onto the delivery truck trailer and unstrapping the load. He accidently stepped backwards and fell off the truck bed and broke his right hand. Brown was seen by the doctor and placed his hand in a cast. The doctor put Mr. Brown on restricted duty for 30 days.
10. 12/10/2018– Eugene Atabanks, shop Forman was driving to work in his personal car and crossed the center lane resulting in a head on collision. He was pronounced dead on the scene by responding authorities.
Use the Excel spreadsheet found in Module 3 Assignment – OSHA Recordkeeping Materials Folder to complete the OSHA 300 and 300A log.