Many community health care centers have been exempt from certain reporting requirements under the Occupational Safety and Health Act (OSHA), but that rule is changing effective January 1, 2015. It is important to review the OSHA changes and make sure you are compliant with all state level and federal regulations.
What you need to know:
What is an illness or injury as defined by OSHA?
According to OSHA (Subpart C 1904.46): An injury or illness is an abnormal condition or disorder. Injuries include cases such as, but not limited to, a cut, fracture, sprain, or amputation. Illnesses include both acute and chronic illnesses, such as, but not limited to, a skin disease, respiratory disorder, or poisoning.
Classification Codes
Old Rule: Previously, health centers could look up their 3-digit Standard Industrial Classification (SIC) to determine if they were exempt.
New Rule: OSHA follows the North American Industry Classification System (NAICS) that provides a 4-digit code to those “partially exempt” due to company size or industry classification. (Here is the link to the new codes: https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html )
Reporting Requirements
Old Rule: If the centers SIC code provided a partial exemption centers were still required to report any work-related fatalities and in-patient hospitalization of three or more employees within eight hours of the event.
New Rule: The “three or more employee threshold” has been removed. Even if you are partially exempt under your NAICS code, you must report any illness or injury that results in:
A fatality that occurs within 30 days of the work-related incident (must be reported within eight hours of the event);
All work-related in-patient hospitalizations (unless the hospitalization was for diagnostic testing or observation). Heart attack hospitalizations are reportable if the event occurred due to a work-related incident;
Amputation or loss of an eye (must be reported within 24 hours of the event).
The Department of Labor (DOL) provides excellent training via their website on OSHA requirements. The materials include PowerPoint presentations and training facilitator materials that may be helpful to review. (Here is the link to training materials: https://www.osha.gov/recordkeeping/RKpresentations.html )
References:
http://www.dol.gov/opa/media/press/osha/OSHA20141697.htm
https://www.osha.gov/recordkeeping2014/records.html
https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html
OSHA Final Rule: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=24728
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