Recordkeeping
Recordkeeping is another time consuming but vital part of Cal/OSHA compliance.
The following table lists the minimum time you must maintain Cal/OSHA-related records:
Injury & Illness Reports – 5 years
Inspection Reports – 1 year
Training Reports – 1 year
Hazardous Materials List – 30 years
Medical/Exposure Records – 30 years
SDS Archive – 30 years
Filing System
Keep individual files organized into the following topics:
If you have elected to use a Safety Committee system, you will need to add a seventh section to document committee activities. Safety committees can help meet certain Cal/OSHA requirements, but there are minimum standards that must be met. Safety committees are not required for veterinary facilities, and the additional requirements placed on employers using this system makes it cumbersome. There are strict requirements for employee representation, meeting schedules, etc. Most veterinary practices will find it easier to meet the communication requirements without the use of safety committees.
I. Safety Training/Meetings
Keep all safety training documentation including CVMA Form 5 – Group Safety Training Documentation. Retain all teaching materials including lesson plans, outlines, notes taken by a staff member during a training, or other training aids such as handouts or pamphlets. Document spontaneous individual employee training by utilizing CVMA Form 6 – Individual Employee Safety Training Documentation. If you utilize self-guided online or computer assisted training for employees, or if you have audio/ video material, document employee use of these resources.
Businesses with fewer than 10 employees have the option of recording safety training through a general log of employee training. CVMA Form 7 – Log of Employee Training is available should you choose this option.
Retain these records for a minimum of one year. The CVMA recommends that you retain these documents for 30 years.
II. Inspection Reports
Retain results of your initial self-inspection with these files. Also file your job safety analyses here. Place dated and signed checklists (CVMA Form 9 – Inspection Checklist) used during monthly inspections, together with a completed Summary and Action Plan (CVMA Form 8 – Inspection Summary & Action Plan), in this file. Be sure to include the correction dates for any deficiencies found during the inspections.
The CVMA recommends monthly inspections, at least initially. If you can document a safe workplace with these monthly inspections, you may be able to justify a less frequent inspection schedule. Be sure to change your written IIPP to reflect your actual inspection interval.
Keep these files for a minimum of one year. You may want to keep documentation supporting a less frequent inspection schedule forever.
III. Exposure Records
Cal/ OSHA standards concerning toxic substances and hazardous exposures require records of employee exposure to these substances and sources, physical examination reports, employment records, and other information.
Employers using any regulated carcinogens have additional reporting and recordkeeping requirements. An example of a regulated carcinogen would be Ethylene Oxide. See Title 8 of the California Code of Regulations for details.
This file is for your radiation exposure records and any other applicable exposure testing (such as waste anesthetic gases, noise, etc.) you may conduct. These records must be maintained for a minimum of thirty (30) years.
*See “Additional Cal/OSHA Requirements” in the main Table of Contents to determine if any other regulations may apply to your practice.
IV. Injury and Illness Investigations
File your completed Injury/Illness Investigation Reports (CVMA Form 4 – Injury / Illness Investigation Report) here and maintain for a minimum of five years. Place each investigation report in a separate folder so that each injury or illness is filed individually. If an employee is injured more than once, do not place the investigation reports in the same folder. In the event that your records are taken by court order, you may be able to give them the individual folder. If all of your reports are in one folder, however, you may have to give them the entire folder with all of the reports.
V. OSHA Log 300
What is OSHA Log 300?
You must record information about every work-related death and about every work-related injury or illness that involves loss of consciousness, restricted work activity or job transfer, days away from work, or medical treatment beyond first aid. You must also record significant work-related injuries and illnesses that are diagnosed by a physician or licensed health care professional. You must also record work-related injuries and illnesses that meet any of the specific recording criteria listed in CCR Title 8 Section 14300.8 through 14300.12. This document should be kept in a confidential location – it should not be posted. If your practice has 10 or fewer employees, you are exempt from this requirement.
What is OSHA Log 300A?
Log 300A is an annual summary of work-related injuries or illnesses reported on Log 300. The summary must be posted for a three-month period from February 1 through April 30. If your practice has 10 or fewer employees, you are exempt from this requirement.
What is OSHA Form 301?
Form 301 is an Illness and Injury Investigation report form and must be completed when a recordable workplace injury or illness occurs. Reportable conditions are: a work-related death, a work-related injury or illness that involves loss of consciousness, restricted work activity or job transfer, days away from work, or medical treatment beyond first aid.
Questions to ask in an accident investigation include:
- What happened?
The investigation should describe what took place that prompted the investigation: an injury to an employee, an incident that caused a production delay, damaged material or any other conditions recognized as having a potential for losses or delays.
- Why did the incident happen?
The investigation must obtain all the facts surrounding the occurrence: what caused the situation to occur; who was involved; was/were the employee(s) qualified to perform the functions involved in the accident or near miss; were they properly trained; were proper operating procedures established for the task involved; were procedures followed, and if not, why not; where else this or a similar situation might exist, and how it can be corrected.
- What should be done?
The person conducting the investigation must determine which aspects of the operation or processes require additional attention. It is important to note that the purpose here is not to establish blame, but to determine what type of constructive action can eliminate the cause(s) of the accident or near miss.
- What action has been taken?
Action already taken to reduce or eliminate the exposures being investigated should be noted, along with those remaining to be addressed. Any interim or temporary precautions should also be noted. Any pending corrective action and reason for delaying its implementation should be identified.
CVMA Form 4 – Injury / Illness Investigation Report has been custom formulated to address these questions and more. It is recommended that you use this form for investigations.
What You Need to Do
File completed OSHA Log 300s in a secure location. Maintain and update these logs for a minimum of five years.
For work-related injuries or illnesses that must be recorded on Cal/OSHA Log 300, you should also complete Cal/OSHA Form 301 in addition to CVMA Form 4 – Injury / Illness Investigation Report. If your workers’ compensation report form has all of the information requested on Cal/OSHA Form 301, a photocopy of this report may be substituted for Cal/OSHA Form 301. The original must remain in your workers’ comp file.
Number each file sequentially—for example, the year/incident: 2016-02. In most cases, where confidentiality is not a requirement, you could also add the employee’s name to this identifier.
Log 300/ 300A Exemption
Employers with 10 or fewer employees are exempt from having to complete and maintain these forms. As with other Cal/OSHA regulations, self-employed individuals or partnerships with no employees are exempt. Corporations must count everyone as an employee, even owners.
Recordable Cases
You are required to record information on work-related injuries and illnesses that result in any of the following. Each event should be recorded on a separate line of the form. You must enter each recordable case within seven (7) days of learning of the event:
- Death
- Loss of consciousness
- Days away from work
- Restricted work activity or job transfer
- Medical treatment beyond first aid
There are some additional criteria that would rarely affect a veterinary facility. These are provided in the Cal/OSHA Log 300 instruction material. The first indicates that needle-stick injuries or cuts from a sharp object that is contaminated with another person’s blood or other potentially infectious material must be recorded. Most needle-stick injuries in a veterinary facility probably would not automatically meet this requirement unless the “sharps” object was contaminated with fluid from an animal suspected or diagnosed as having a disease like rabies, brucella, leptopirosis or other zoonotic disease.
Medical Treatment
The Cal/OSHA instructions include this statement: “Medical treatment includes managing and caring for a patient for the purpose of combating disease or disorder.” The instructions then go on to list procedures that are not considered medical treatments and are therefore not recordable (see list later in this discussion). The list below was prepared from an earlier version of Cal/OSHA instruction material and is reprinted here to help determine when you must record an injury or illness. This list does not appear on current Cal/OSHA forms.
The following are examples of medical treatment beyond first aid, and if provided to the employee, require an entry on the log:
- Treatment of infection
- Treatment for second- or third-degree burns
- Sutures
- Foreign body embedded in the eye
- Complicated foreign body removal (more than a simple sliver)
- Prescription medications
- Surgical debridement
- Positive X-ray diagnosis
- Hospitalization for treatment
Any of the following, usually considered first aid, would not require recording the event.
- Using non-prescription medications at non-prescriptions strengths
- Administering tetanus immunizations
- Cleaning, flushing, or soaking wounds on the skin surface
- Using wound coverings, such as bandages, BandAids™, gauze pads, etc., or using SteriStrips™ or butterfly bandages
- Using hot or cold therapy
- Using any totally non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc.
- Using temporary immobilization devices while transporting an accident victim (splints, slings, neck collars, or back boards)
- Drilling a fingernail or toenail to relieve pressure, or draining fluids from blisters
- Using eye patches
- Using simple irrigation or a cotton swab to remove foreign bodies not embedded in or adhered to the eye
- Using irrigation, tweezers, cotton swab or other simple means to remove splinters or foreign material from areas other than the eye
- Using finger guards
- Drinking fluids to relieve heat stress.
Privacy Case
There are some cases in which you should not enter the employee’s name on the Log 300. These include;
- An injury or illness to an intimate body part or to the reproductive system
- An injury or illness resulting from a sexual assault
- A mental illness
- A case of HIV infection, hepatitis or tuberculosis
- A needle-stick injury or cut from a sharp object that is contaminated with blood or other potentially infectious material (see CCR Title 8, §14300.8 for definition)
- Other illness, if the employee requests that his or her name not be entered on the log.
In these cases, “Privacy Case” should be entered in the space normally used for the employee’s name, and you must maintain a separate, confidential list of the case numbers and employee names. This list of privacy concern cases is to be used to update the cases and provide information to the government when asked. Please refer to Cal/OSHA’s instruction material for details.
Posting Requirements
The summary portion of the log (Form 300A) must be posted by February 1 and remain posted through April 30, showing the totals for your practice for the previous year only for companies with more than 10 employees. This summary must be posted even if no injuries or illnesses were recorded. The form must be signed by an individual who can certify that the totals are correct. Don’t post the original Log 300, only the Form 300A summary portion.
Injury and Illness Reporting Requirements
In addition to the recording requirements listed above, you are required to report immediately to Cal/OSHA any occupational fatality, serious injury, or serious illness. The report must be made by telephone. Fed/OSHA defines “immediately” as within 8 hours.
Serious injury or illness means any injury or illness that causes permanent disfigurement or hospitalization for more than 24 hours.
VI. SDS Collection (Archive)
Safety Data Sheets for chemicals on your practices hazardous chemical list should be archived even if use of the chemicals is discontinued in your practice. These documents must be maintained for at least 30 years. Your active collection should be maintained in an area readily accessible by employees. SDS’s for items no longer used should be filed in an archive collection organized in a similar fashion to your active collection, but should not be intermingled with the active collection.
More information on Cal/OSHA recordkeeping requirements can be accessed at: http://www.dir.ca.gov/dosh/etools/recordkeeping/index.html
