CALIFORNIA LAW ON LOG 300
As of the start of 2016, the California Occupation Health & Safety Standards Board has not approved of the changes to the recordkeeping guidelines. This process can take up to six months, essentially pushing the compliance date to January 1, 2017.
In summary, auto dealers in California are currently exempt from Log 300 requirements. See https://www.dir.ca.gov/dosh/DoshReg/FinalEmpRec.html. Cal/OSHA has inspected dealers for regulatory violations and has not requested to see the Log 300 as they are exempt per state regulations.
FEDERAL LAW ON LOG 300
On January 1, 2015, Fed-OSHA required auto dealers to keep a record of occupational injuries and illnesses using the forms as follows:
- Log of Work-Related Injuries & Illnesses (OSHA Form 300)
- Injury & Illness Incident Report (OSHA Form 301)
- Summary of Work-Related Injuries & Illnesses (OSHA Form 300A)
Forms with Summary Calculations (Excel): https://www.osha.gov/recordkeeping/RKforms.html (3rd link)
OSHA Guide On Completing Forms: https://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf
Tutorial for Completing Forms: https://www.osha.gov/recordkeeping/tutorial.html
First-Aid: is not recordable, https://www.osha.gov/recordkeeping/firstaid_list.pdf
Recordkeeping Questions & Answers: https://www.osha.gov/dte/grant_materials/fy10/sh-20856-10/Recordkeeping_Questions_w_Answers.pdf
Posting Requirements: The summary log, Form 300A (for 2015), must be posted on the employee notice board from February 1 to April 30, 2016.
See our October 2014 Newsletter on Log 300 at http://epaoshablog.com/2014/10/23/accident-reporting-to-osha-injury-log-requirements/.
FIRST-AID KITS AND THE NEW ANSI STANDARD
California and Federal regulations mandate that employers ensure availability of medical personnel for advice on matters of industrial health or injury. In response, most dealerships have contracted with a clinic for the treatment of injuries at the workplace, making them compliant with regulations. Also required in the Federal & California standards is the availability of a first-aid kit at the workplace. In 2015, American National Standards Institute (ANSI) updated the old first-aid kit content standard and now has the new ANSI/ISEA Z308.1-2015 Workplace First-Aid Kits and Supplies standard. ANSI 2015 compliant kits are split in 2 different classes (Class A and Class B) and now include more required items, plus items in increased quantities.
The Class A Kit includes contents designed for the most common workplace injuries while the Class B kit includes a broad range of supplies for complex or high-risk environments. We note that the new 2015 ANSI standard has some antibiotic application, antiseptic, burn dressing, and burn treatment requirements that were not present in the old 2003 standard. The sales machinery of vendors and distributors are knocking on the doors of dealerships demanding that they comply with the new standard. To the unwary, the vendors often sell items for the first-aid kit, such as anti-diarrheal and antacid, which are not required under the old or the new standard and are a waste of money. Kits should be inspected at least monthly to ensure the completeness and usability of all first-aid supplies. Expired items should be discarded and replaced.
|CLASS A First Aid Kit: ANSI/ISEA Z308.1-2015, Required Minimum Fill|
|16 Adhesive Bandage 1 x 3 in.|
1 Adhesive Tape 2.5 yd (total)
10 Antibiotic Application 1/57 oz.
10 Antiseptic 1/57 oz.
1 Breathing Barrier
1 Burn Dressing (gel soaked) 4 x 4 in.
10 Burn Treatment 1/32 oz.
1 Cold Pack 4 x 5 in.
2 Eye Covering w/means of attachment 2.9 sq. in.
|1 Eye/Skin Wash 1 fl. oz. total|
1 First Aid Guide
6 Hand Sanitizer 1/32 oz.
2 pr Medical Exam Gloves
1 Roller Bandage 2 in. x 4 yd.
2 Sterile pad 3 x 3 in.
2 Trauma pad 5 x 9 in.
1 Triangular Bandage 40 x 40 x 56 in.
Cal/OSHA: Regulations mandate that a first-aid kit approved by a consulting physician be available on the premises for every work person on the job. A consulting physician is a medical doctor who is well versed with dealership operations and has knowledge of typical hazards and accidents on the job. Dealerships must contact their local MD for a first-aid kit list to help them fill their kit under the new 2015 ANSI standard. (Ref: T8CCR3400 (a) and (b)).
Fed-OSHA: Regulations state that an employer must have “adequate first-aid supplies…readily available,” although specific first-aid supplies are not listed. There is no minimum requirement, but the statute does make a reference to ANSI Z308.1-2003 Minimum Requirements for Workplace First Aid Kits. The 2015 standard, as noted above, has some advantages over the 2003 standard, so the employer should seek guidance from a person competent in first-aid and develop a new list for the first-aid kit. (Ref: 29CFR1910.151(b)).
Download: January 2016 Newsletter