The Occupational Safety and Health Administration (OSHA) requires all dairy employers to provide a safe and healthful workplace free of recognized hazards and follow all applicable standards. Click here to view one of these standards, OSHA Recordkeeping regulation (29 CFR 1904). According to the recordkeeping standard, employers are required to prepare and maintain records of occupational injuries and illnesses.

This information is important for employers, workers and OSHA in evaluating the safety of a workplace, understanding industry hazards and implementing worker safeguards to reduce and eliminate hazards.

Who needs to do recordkeeping?
If a dairy operation had more than 10 (non-family) employees at any point in time in the previous year (January 1 to December 31), then the operation must maintain OSHA-300, 300A and 301 injury and illness records.

What should be recorded?
Dairy employers who are subject to the recordkeeping requirement as outlined above are required to record work-related injuries and illnesses that result in the following: death, days away from work, restricted work activity or job transfer, loss of consciousness and medical treatment beyond first aid.

Employers must record any significant work-related injuries and illnesses that are diagnosed by a physician or other licensed health care professional, such as any work-related case involving cancer, chronic irreversible disease, a fractured bone or a punctured eardrum.

Injuries and illnesses are work-related if: (1) An event or exposure in the work environment either caused or contributed to the resulting condition, or (2) an event or exposure in the work environment significantly aggravated a pre-existing injury or illness (results in greater consequences).

OSHA provides clarification of what constitutes first-aid (non-recordable) versus medical treatment (recordable) for purposes of OSHA recordkeeping.
• Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes)

• Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment for recordkeeping purposes)

• Cleaning, flushing or soaking wounds on the surface of the skin

• Using wound coverings such as bandages, Band-Aids, gauze pads, etc.; or using butterfly bandages or Steri-Strips (other wound closing devices such as sutures, staples, etc., are considered medical treatment for recordkeeping purposes)

• Using hot or cold therapy

• Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes)

• Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.)

• Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister

• Using eye patches

• Removing foreign bodies from the eye using only irrigation or a cotton swab (removing foreign bodies from the eye using tweezers is considered medical treatment for recordkeeping purposes)

• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means

• Using finger guards

• Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes)

• Drinking fluids for relief of heat stress

OSHA also has exceptions to recordable injuries/illnesses suffered while at work.

The injury/illness may not be recordable if it falls under one of the following exceptions [29 CFR 1904.5(b)(2)]:
• Eating and drinking of food and beverages

• Personal grooming, self-medication, self-inflicted

• Personal tasks at establishment outside of assigned working hours

• Motor vehicle accidents on company property while the employee is commuting to or from work

• Common cold and flu

• Blood donations

• Exercise programs or recreational sports

• Mental illnesses unless diagnosed as work-related.

Recordkeeping forms
OSHA has designated forms to help the employer and OSHA develop a picture of the extent and severity of work-related incidents. The OSHA 301 Injury and Illness Incident Report is the first form to be completed when a recordable work-related injury or illness has occurred.

An equivalent form can be used if it has the same information, is as readable and understandable, and uses the same instructions as the OSHA form it replaces.

Dairy employers are required to use the OSHA Form 300 Log of Work-Related Injuries and Illnesses to classify work-related injuries and illnesses and to note the extent and severity of each case.

Employers are also required to keep a separate Summary of Work-Related Injuries and Illnesses (Form 300A). OSHA Form 300A (for the preceding year) must be certified by a company executive and posted in a common area for the duration of February 1 through April 30.

If employees will not see the form in its posting area, copies should be made available to them. Employers must enter each recordable case on the forms within seven calendar days of receiving information that a recordable case occurred.

Forms can be kept on a computer as long as they can be produced when they are needed (i.e., meet the access provisions of 29 CFR Subparts 1904.35 and 1904.40). Click here to view all OSHA recordkeeping forms and instructions for completing.

Reporting to OSHA
OSHA requires (29 CFR Subpart 1904.39) that all employers must report any employee death from a work-related incident or the in-patient hospitalization of three or more employees within eight hours.

Employers must orally report the fatality/multiple hospitalization by telephone or in person to the Area OSHA office that is nearest to the site of the incident. Employers may also use the OSHA toll-free central telephone number 1-800-321-OSHA (1-800-321-6742).

Resources
Click here to view recent webinars addressing OSHA recordkeeping requirements and instructions for form completion for the dairy industry.

Future articles
Upcoming articles will address regulatory standards and best practices related toworker safety and health issues such as chemical hazards, manure pits, safety training, safe machinery operation, livestock-handling, emergency preparedness and human resource management. PD

Those with specific questions about complying with health and safety regulations can leave a comment below or click here to email Douphrate directly.

Dr. David Douphrate is an assistant professor at the University of Texas, School of Public Health. Douphrate conducts research and outreach related to worker health and safety through the High Plains and Intermountain Center for Agricultural Health and Safety (HICAHS), headquartered at Colorado State University.

Douphrate and his HICAHS colleagues conduct research and outreach with dairy producers to improve safe working environments while simultaneously improving dairy productivity and efficiency. Mary Bauer is a compliance assistance specialist for the Wisconsin Eau Claire OSHA Area Office. Dr. William Brazille is an assistant professor and Kyle Root is a graduate student at Colorado State University.

Click a link below to view previous columns by Douphrate and his colleagues:
• Dairy worker safety and health: OSHA inspections, citations and penalties
• Dairy worker safety and health: A new column from David Douphrate