OSHA rules bring more paperwork

The new year will bring new paperwork requirements for many drycleaners due to revisions by OSHA of its on-the-job accident and illness reporting rules.

The OSHA requirements have been around for 30 year,s but until now, drycleaners have been exempt except for reporting the most serious types of accidents — those resulting in death or in hospitalization of three or more workers. But under revised rules that go into effect Jan 1, drycleaners with more than ten employees will lose that exemption and will need to become familiar with three OSHA forms for recording work-related injuries and illnesses.

The 10-employee cut-off will keep many drycleaners exempt from reporting all but the most serious cases, but in calculating the number of employees, OSHA counts part-time workers as full employees, and all of a company’s employees are counted, even if they work at different locations. For example, a drycleaning operation that has a main plant with five employees and three drop stores with two part-time employees each would be considered to have 11 employees and would not be exempt.

OSHA also bases the employee count on the highest number employed at any time during the calendar year. Thus if that drycleaning operation had only four employees at the main plant for all of the year except for a brief period during the busy season, the company would still be subject to the full set of requirements.

Employers who are not exempt from the OSHA requirements must prepare and maintain records of work-related injuries and illnesses. Three forms are involved:

The Log or Work-Related Injuries and Illnesses (Form 300) is used to list injuries and illnesses and track days away from work, restricted job duties, or job transfers.

Injury and Illness Report (Form 301) is used to record supplementary information about recordable cases. OSHA allows employers to use a workers’ compensation or insurance form for this purpose if it contains the same information.

The Summary (Form 300A) is used to show totals for the year in each category. The summary is posted in the workplace from Feb. 1 to April 30 each year.

The forms and other compliance information are available on OSHA’s web site: www.osha.gov. The forms and information developed specifically to help drycleaners meet the requirements were published in the September issue of IFI’s Fabricare News (Legislative and Regulatory Overview No. 22).

Forms 300 and 301 must be completed within seven calendar days of receiving information that a recordable incident has occurred. The annual summary for the last calendar year must be posted by February 1. The forms must be saved for five years. Reports do not need to be filed directly with the government, but the forms must be made available to an OSHA inspector within four hours of a request.

Injuries and illnesses that must be recorded include those that are work-related, results in death, days away from work, restricted work duties or transfer to another job or require medical treatment beyond first aid of loss of consciousness.

IFI said that a case meets this criteria if it involved a significant injury or illness diagnosed by a physician or other licensed heath-care professional, even if it doesn’t meet the other criteria.

IFI also described several other types of incidents that must be recorded even if they don’t meet the previously described criteria. Those include:

• Work-related needle stick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material.

• Incidents in which an employee is medically removed under the medical surveillance requirements of an OSHA standard

• Exposure of an employee to anyone with a known case of active tuberculosis.

OSHA has delayed the effective date of reporting requirements for hearing loss and musculoskeletal disorders (MSDs) for at least a year.

OSHA also requires employers to provide information to employees about the reporting requirements and to establish a procedure for employees to report injuries and illnesses. The rule specifically prohibits employers from discriminating against employees who make a report and employees must have access to the 301 forms so they can review their records of their own injuries and illnesses.

OSHA says that about 1.4 million employers are subject to these record-keeping requirements. The agency plans to mail out new record-keeping forms to those employers in early December.

As part of its outreach effort to help employers meet the new and revised requirements, OSHA is providing material on its web site, including a brochure to help employers determine if they are covered by the rule, several fact sheets, PowerPoint training programs and downloadable copies of the forms and instructions for completing them.

More compliance assistance is planned for the web site. This will include a FAQ (Frequently Asked Questions), an interactive “e-tool” to guide employers and a compliance directive to provide guidance to OSHA inspectors. Printed materials are available from OSHA’s Publications Office, (202) 693-1888.


	OSHA rules bring more paperwork The new year will bring new paperwork requirements for many drycleaners due to revisions by OSHA of its on-the-job accident and illness reporting rules. The OSHA requirements have been around for 30 year,s but until now, drycleaners have been exempt except for reporting the most serious types of accidents — those resulting in death or in hospitalization of three or more workers. But under revised rules that go into effect Jan 1, drycleaners with more than ten employees will lose that exemption and will need to become familiar with three OSHA forms for recording work-related injuries and illnesses. The 10-employee cut-off will keep many drycleaners exempt from reporting all but the most serious cases, but in calculating the number of employees, OSHA counts part-time workers as full employees, and all of a company’s employees are counted, even if they work at different locations. For example, a drycleaning operation that has a main plant with five employees and three drop stores with two part-time employees each would be considered to have 11 employees and would not be exempt. OSHA also bases the employee count on the highest number employed at any time during the calendar year. Thus if that drycleaning operation had only four employees at the main plant for all of the year except for a brief period during the busy season, the company would still be subject to the full set of requirements. Employers who are not exempt from the OSHA requirements must prepare and maintain records of work-related injuries and illnesses. Three forms are involved: The Log or Work-Related Injuries and Illnesses (Form 300) is used to list injuries and illnesses and track days away from work, restricted job duties, or job transfers. Injury and Illness Report (Form 301) is used to record supplementary information about recordable cases. OSHA allows employers to use a workers’ compensation or insurance form for this purpose if it contains the same information. The Summary (Form 300A) is used to show totals for the year in each category. The summary is posted in the workplace from Feb. 1 to April 30 each year. The forms and other compliance information are available on OSHA’s web site: www.osha.gov. The forms and information developed specifically to help drycleaners meet the requirements were published in the September issue of IFI’s Fabricare News (Legislative and Regulatory Overview No. 22). Forms 300 and 301 must be completed within seven calendar days of receiving information that a recordable incident has occurred. The annual summary for the last calendar year must be posted by February 1. The forms must be saved for five years. Reports do not need to be filed directly with the government, but the forms must be made available to an OSHA inspector within four hours of a request. Injuries and illnesses that must be recorded include those that are work-related, results in death, days away from work, restricted work duties or transfer to another job or require medical treatment beyond first aid of loss of consciousness. IFI said that a case meets this criteria if it involved a significant injury or illness diagnosed by a physician or other licensed heath-care professional, even if it doesn’t meet the other criteria. IFI also described several other types of incidents that must be recorded even if they don’t meet the previously described criteria. Those include: • Work-related needle stick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material. • Incidents in which an employee is medically removed under the medical surveillance requirements of an OSHA standard • Exposure of an employee to anyone with a known case of active tuberculosis. OSHA has delayed the effective date of reporting requirements for hearing loss and musculoskeletal disorders (MSDs) for at least a year. OSHA also requires employers to provide information to employees about the reporting requirements and to establish a procedure for employees to report injuries and illnesses. The rule specifically prohibits employers from discriminating against employees who make a report and employees must have access to the 301 forms so they can review their records of their own injuries and illnesses. OSHA says that about 1.4 million employers are subject to these record-keeping requirements. The agency plans to mail out new record-keeping forms to those employers in early December. As part of its outreach effort to help employers meet the new and revised requirements, OSHA is providing material on its web site, including a brochure to help employers determine if they are covered by the rule, several fact sheets, PowerPoint training programs and downloadable copies of the forms and instructions for completing them. More compliance assistance is planned for the web site. This will include a FAQ (Frequently Asked Questions), an interactive “e-tool” to guide employers and a compliance directive to provide guidance to OSHA inspectors. Printed materials are available from OSHA’s Publications Office, (202) 693-1888.