Document 3QYBYQpO7XgXpoxdm9042qgJ3

SAFETY HE5UT3 NAN . n' \ A A ' <* j V >. ^ : StCTtON * !w 7, Mart* 1W B&i. SYSTEM SAFETY RESULTS PLAN SECTION II RECORDING AND REPORTING OCCUPATIONAL INJURIES AND ILLNESSES FEDERAL REGULATIONS contents t 1. reRAi ................................................. 2. LOO Of OCCUPATIONAL INJUNB AMD JO- J. SUPPUMWIAIY tCCOAO OP OCCUPA TIONAL MUMS AMO aiMBSCS . . . 4. SUMMAftY OP OCCUPATIONAL MAMAS ANOAIMSaS .................................... 5. OSMA SUtVfY............................................ 1.07 This section contains information regarding Part 1904 of Title 29, Code of Federal Regulations--Recording and Reporting Occupational Injuries and Illnesses. 1.02 ReconttMpiaf Uadr Approved State Plane As stated in Section 1904JQ of Title 29, "Records maintained by an employer and reports submitted pursuant to, and in accordance with, the requirements of an approved State Plan under Sec tion 18 of the Act shall be regarded as compliance with this Part 1904." '.(W Peaa/ties: As stated in the Act, Whoe'-rr knowingly makes any false statement repre sentation. or certification in any application, record, plan. or other document filed or required to be main tained pursuant to this Act shall, upon conviction, be punished by a fine of not more than $10,000. or by :mpriscnm*nc for net more than b mouths, or by both." ,.ia variance from ttscorttkoepiag Ht q .<fi aery* Th= AT&T petitioned for. end re ceived from, the Department of Labor a variance from recordkeeping requirements. The following is an excerpt from tbe Federal Register, Document 7210873. filed July 1L 1972. DEPARTMENT OF LABOR Bureau of Labor Statistics OFFICE OF ASSISTANT COMMISSIONER FOR OCCUPATIONAL SAFETY AND HEALTH STATISTICS Notice of Variance From Recordkeeping Requirements In accordance with Section file) of the Williams-Steiger Occupational Safety and Health Act of 1970 (29 U.S.C. 656). and 29 CFR l904JgJ, notice is hereby given that the American Telephone & Telegraph Co. (AT&T) has been given permission to maintain certain records in a manner different from that set forth in 29 CFR Part 1904. AT&T baa for many years kept records for its field operations on the basis of occupational groups subject to comparable hazard exposure and has appropriately petitioned for permission to con tinue this procedure contending that it provides the most useful statistics for the evaluation of accidents incurred by its employees and that <rnjverstoo of its methods which apply to over 16.000 establishments to conform to the establishment basis required by 29 CFR Pan 1904 would be unduly costly. After carefully coasidering the petition the contentions contained therein have been de:ermineo' to be 'veil founded and it has therefor? beer granted. the full petition ia available tor public insp<icittjr 3.'-.d copying at the Office of 0ccoo3--iontl mm* PLAINTIFF'S EXHIBIT ATT-239 LLA 001391 tSS 5KTION ij SARTY MSU.TS HAN Safety and Health Statistics. Room 3818, 441 G Street NW, Washington, DC if&W Signed at Wash ington. DC. this 6th day of July 1972. Thomas J. McArdle Assistant Commissioner for Occupational Safety and Health Statistics l. IOG Of OCCUPATIONAL MAIMS ANO tUMBSB 2.01 General: The OSHA regulations require every employer to maintain a log of recordable occupational injuries and illnesses. (a) OSHA Form 100 was provided for this purpose for calendar years 1972 through 1977. A sub stitute form, as described in (cl below, was accept able. Ibi OSHA Form 200 is provided for this purpose for calender yean 1979 and later. A substitute fom, as described in (c) below, is acceptable. tc Substitute forms, such as printouts from data processing equipment, are acceptable if they are as legible and comprehensible as OSHA Form 200. 2.02 Imdividasl Loft; Logs of Occupational In juries and Illnesses shall be maintained within the Bell System in accordance with the official instructions, with the following interpretations ap plied: (ai Field Force One log shall be maintained for each departmental district organisation. The Held kg location shall be the district office. (bi Other Forcee: One log shall be maintained for eaeb building location to which employees report regularly, eg, Headquarters buildings, ac counting buildings, etc. One office within the building shall be designated as the building log 'ocatioo. :c) Mixed Forcee: Where all or a portion of a field operating district is located in a building which would otherwise be considered a headquar ters itg. Operator Services located in Company or Area Headquartersi. the field operating personnel 'hall be included iu tbe departmental district !og and not in the building log. jVrue- m no case shall an individual fog ccnjx"\ j::u:c3 for more than one state. Sbedd - field district include establishments in more than one state, separate logs shall be main tained for each 3tate. 2.03 Recordable Cases: Occupational injury and illness cases shall be recorded according co the rules set forth in the official government regu lations. Questionable cases shall be recorded on the appropriate tog and the facts forwarded through line* of organization to the AT4T, Manager-Safety, for a decision. If the case is ruled not recotdable, it shall be stricken from the log. 2.04 Reeerdkeepimg Method*: Either of two recordkeeping methods are permitted by OSHA: la) Localized recordkeeping in which all records are prepared and maiatained within the local establishment. tb) Centralised recordkeeping in which the legt, supplementary records, and luminaries are prepared and maintained at a central location and copies are forwarded to field localities periodical ly- it is anticipated that Bell System Companies will maintain records centrally. Uniform control is vital to this reporting plan, which woald be extremely dif ficult. if not impossible, without centralized recordkeeping. 2.05 Time Requirement*: (a) If the employer is utilizing the localised recordkeeping method, the employer shall enter each recordable occupational injury or ill ness on the log as early as practicable but no later ihan 6 working days after receiving information that a recordable case has occurred. lb) If the employer is utiliziag the centralised recordkeeping method, tbe records must be maintained in compliance with the following two requirement*: fl) At the cmitnlized recordkeeping location, sufficient information is available to (d- plete the tog to a date within 6 working days after receiving information that recordable :ase has occurred. At each of th.* field or building locstioaa described't paragraph .'.02. a com- cf th: LLA 001392 SAFETY mum nan ISS 7, SECTION II log (and associated Form K-15) for that location is available which is complete and current to a date within 45 calendar days. 2.0* Updating: If any change occurs in a case al ready recorded on a log (ie, a relapse, redaaaificatkm, etc), the new information shall be eatered to supersede the earlier entry. This applies for the entire period the log is retained (current year pins 5-y v retention period). (a) The number of absence days and/or the num ber of leatrictiaa days for each ease need not be entered on the log nor updated until the final onteewie of the esse is actually determined except for the annual end-of-year summary. (b) Year-end requirements far Bell Systeas <. -enpetioaal reports will be similar to QSHA re quirements as follows: (1) If a ease is still pending at the end of the year, an estimate must be made for the number of absence days and the number of re striction days for the esse. These estimated days most be entered into the Safety Computer System. After that year's data has seen re moved from the active part of the Safety Com puter System's data base, the log will be manually updated for that case until the em ployee returns to the job or the retention period required by OSHA has elapsed. *2) Year-end summary reports will include the estimated days for those eases still pending. (3) if the final outcome of such a pending case is determined within the next year lie, while the case is still in the active'part of the Safety Computer System's data base), a revi sion should be entered into the Safety Computer System to replace the estimated abseace days and restriction days with the actual days in volved. 14) If the final outcome of such a pending case is not determined within the next ye^r. a second estimate should be made for the number of absence days and the number of restriction days for the ease at the end of the second year : ie. immediately prior to removin': the case from the active part of the Safety Computer System's data base). lot Access to Log: The Logoi Occupational in juries or illnesses shall not be posted '"or gen eral viewing, it shall remain in the custody of appropriate management personnel to be produced upon demand by authorized Government Officials or for management information. (a) Federal regulations also require that all em ployees. former employees, and employee representatives be given access to the Log of Occu pational Injuries sad Illnesses for any establish ment in which the employee is or has been employed. (b) Due to the Bell System recordkeeping variances, thenars many situations where an employee's normal place of reporting is located a coasidersbie distaste from the log location, mak ing physical access difficult. The text of the regu lation states that the log shall be nude available in a reasonable manner and at reasonable times. In these cases where the log location is aot conve nient to the requesting employee, a copy of the log can be mailed to the employee's supervisor, who can then make it available to the employee. 2. M Compliance VUitm When an OSHA Com pliance Officer asks to see the log during a compliance virit. it shall be delivered to him/her, if possible, without delay. Otherwise, he/she shall be placed in immediate telephone contact with the Held or building log location. All information requested by telephone shall be provided verbally and a copy of the log either mailed or delivered later to the officer as requested. To avoid confusion and undue delay, ail managementperaoanel mast be aware of this procedure. 7.09 Reteetioa Period: At the beginning of each calendar year, a new log shall be started for each location described in paragraph 2.02. The log for the previous rear shall be dosed as of December 31. A copy of each year's log shall be retained at the loca tion involved for a period of 5 yean following the year under report. The OSHA Compliance Officer may require past as well as current logs during an inspection. 3. sumEMBfnurr tccon of occupational IN JURIES AND IUNBSS 3.0t General' In addition :o the Log of Occupa tional Injuries and Illnesses, a supplementary form containing certain information about each re cordable injury or illness is required. OSHA Form BS7. sacnoNi SAffTY RESULTS RAN 101 is provided for this purpose, bat another form is acceptable if it contains, at a minimum, the items of information contained on the reverse side of OSHA Form 101. *.02 Form K-1S: Bell System Employee Injury and Illness Report is an acceptable substitute for OSHA Form 101. 3.09 TtmoSeqmbromoatM: Copies of the Supple mentary Record, in connection with each re cordable injury or illness, most resell both the involved recordkeeping center and the field or build ing location (as defined in paragraph ZOZ) within 6 working days after receiving information that a re cordable ease has occurred Sotos The OSHA regulations require that the occurrence of an employment accident, which is fatai to one or more employees or which results in hospctalixatioa of five or mors epiphyses, shall be reported to the nearest of fice of the Area Director of the Occupational Safety and Health Administration. UJ5. De partment of Labor, within 48 horn. (An ap proved State OSHA Plan may have a different time requirement) The reporting may be by telephone or telegraph. Within the Bell System, the initial report shall be by telephone. Whether or not treatment wae provided and length of stay in the hospital are not factors to be considered in reporting. 3L0e Retention Pojfotk All Supplementary Records, including ryflassrfieatMas, relapses, etc, shall be filed with the log to which they relate sad retained for 5 years following the end of the cal endar year in which they were prepared. 4. SUMMARY OP OCCUPATIONAL MJUMB AND U- 4.01 Gonerah A summary of occupational inju ries and iTlniises shall be prepared at the end of each calendar year. (a) OSHA Form 108 was provided for this purpose for calendar years 15772 through 1977. Substi tutes far OSHA Form 108 were not acceptable. (b) OSHA Fora 200 is provided for this purpose for calendar years 1978 and later. A substitute form, such as a printout from data processing equipment, is acceptable if it is as legible and com prehensible as OSHA Fora 200. 4.03 Individual Summaries; A separate sum mary shall be prepared for each field or build ing location described in paragraph 2.02. Where no injuries or Dloesses occurred during the year, sens must be entered on the totals line and the fora post ed. 4.03 Certification: Each summary shall be certi fied as true and complete by the individual responsible for the supervision of its preparation. Certification shall be accomplished by affixing a sig nature, tHIt, and data at the bottom of tha summary. 4.04 ANMg Loomitioma: OSHA Form 200 shall be folded between column F (Description of Injury or TWnesc) and caiman I (Enter Date of Death); oaiy the right-haad portion, columns 1 through 13. ahall be posted. Sufficient copies of each summary shall be made for posting in each location within the seminary ares to which employees report regularly. A copy of the summary shall be posted at every location requiring an OSHA notice poster. 4.05 Ttmo SiniwiMHlK All copies of each summary ahall he posted no later than Febru ary 1 following the rahrwriar year under report and shall remain posted until Much 1. after which oae copy shall be filed with the log to which it relates sad retained for 5 calendar years following the end of the year under report. All additional copies msy be de stroyed after the posting period. S. OSHASURWY S.01 Goaormk The OSHA will notify selected employers each year that they are required to file reports based upon the summaries described in Part 4 of this section. Selected employe! > will receive questionnaires (OSHA Fora 2006) indicating the location to be reported. The report is mandatory and mast be filed within 21 days of receipt of the ques tionnaire. $.02 Report Location: If the report locatiou des ignated in the mailing address block of OSHA Form 200S involves more than one establishment. tk> questionnaire will require consofidathm of informa tion from aO establishments involved. $.03 SotabBakmeak One establishment shall be counted for each field or building location de scribed in paragraph 2.02. tege 4 LLA 001394 LLA 001395