Document G68n6KdezZn4KrDbb6pZqX8wn

Shell Oil Company One Shell Ptiza P.O. Box <320 Houston, Texas 77210 April 28, 1989 Shell Oil Company Houston, TX J. S. Choute E. de Cardenas J. P. Chadwick H. L. Kusnetz 0. D. Long E. W. Montgomery S. L. Schertz Shell Pipe Line Corporation Houston, TX J. W. Holden Shell Mining Company Houston, TX I. P. Jenkins SUBJECT: RECORDKEEPING GUIDELINES FOR OCCUPATIONAL INJURIES AND ILLNESSES Attached is the latest proposal for an amended HS&E Procedure for Implementing BLS Recordkeeping Guidelines for Occupational Injuries and Illnesses. Your comments at the March 28 S4G meeting, and subsequent written-responses to our April 10 revised version, have been considered ,in this latest revision. No changes have been made in the document before paragraph headed "Date of Occurrence" on Page 5. We will seek your approval of the amended Procedure at the May 2 S*G meeting. As agreed earlier, all provisions of the Procedure, including the guidance in the new sections, will be applicable to all cases with dates of occurrence on or after January 1, 1984. We would appreciate your questions or concerns, if any, before the May 2 meeting. Yoi^rs try)y, J. L. Rivard, Manager Regulations & Safety Services JLR/QJM:1fw Attachment LAM 024167 CAS8911702 - 0001.0.0 * ABS-007347 cc: B. F. Aurelius K. C. Crawford J. Davisi/ G. L. Greene M. G. Kohnke Q. J. Machac D. E. Miller C. F. Phillips C. E. Ross MS&E-AS (2) 3 CAS8911702 - 0002.0.0 lam 024168 ABS-007348 * HS&E PROCEDURE FOR IMPLEMENTING BLS RECORDKEEPING GUIDELINES FOR OCCUPATIONAL INJURIES AND ILLNESSES EFFECTIVE JANUARY 1, 1987 AMENDED APRIL 1989 CAB8909701 SHELL OIL COMPANY DIVISIONS AND SUBSIDIARY COMPANIES LAM 024169 ABS-007349 * PREAMBLE 2 In September 1986, the Bureau of Labor Statistics (BLS) published Recordkeepinq Guidelines for Occupational Injuries and Illnesses, revising and replacing the 1978 BLS Guideline known as Report 412-3. The Office of Management and Budget (0MB) has indicated that these new Recordkeeping Guidelines are supplemental instructions to the mandatory OSHA record keeping forms. The existing instructions on the OSHA 200 recordkeeping form are specifically referenced by Federal regulation 29CFR 1904.2(a). The new Recordkeeping Guidelines, positioned as supplemental instruc tions, may have greater regulatory significance than Report 412-3 and its precursors. The Shell OSHA Statistics Recording Guide has served as Shell's guideline for OSHA injury/illness recordkeeping. The Shell OSHA Statistics Recording Guide is now being replaced by the new BLS Guidelines. This HS&E Procedure is intended to assist transition to the new BLS Guidelines. The transition should be effected immediately and be in place by January 1, 1987. These instructions are provided to Shell Oil Company Subsidiary Companies as a service pursuant to a Service Agreement. An HS&E Procedure is a document describing a particular way of accomplishing an activity, which has been developed to assist effective implementation of that activity throughout Shell. A procedure may be modified to adapt to needs of a specific organization by agree ment between that organization and the respon sible HS&E department. This HS&E Procedure has been approved by the HS&E Safety and Industrial. Hygiene Manager and by the func tional managers responsible for this particu lar health and safety issue. CAB8909701 LAM 024170 ABS-007350 r Nv HS&E PROCEDURE FOR IMPLEMENTING BLS RECORDKEEPING GUIDELINES FOR OCCUPATIONAL INJURIES AND ILLNESSES 3 GENERAL OSHA requires, and Shell has in place, systems to record occupational injuries and illnesses. Experienced recordkeepers are familiar with the concepts. Nevertheless, those persons responsible for recordkeeping decisions must understand the entire new BLS Guidelines, particularly Chapter V which deals specifically with recordabi1ity decision-making criteria. The decision-making logic chart (p. 29) is unchanged, as are the basic concepts. However, there are changes and clarifications that must be understood to ensure that decisions are in accord with the BLS Guidelines. The most important are addressed below. WORK RELATEDNESS (Chapter V, Section C, p. 32-37) The BLS Guidelines assert that any injury or illness occurring on the employer's premises is presumed to be work related. Certain exceptions are noted (C-2 and C-3, p. 33). Further, this presumption is rebuttable (C-7 and C-8, p. 34), but only within narrow limits. Shell recordkeepers shall strictly adhere to the guidelines in Section C but may rebut the work-related presumption when facts justify. On premises cases and other questionable work-related cases shall be entered in the log within the time frame stated in the law (six workdays). If, after investigation, an incident is judged not to be work related, the entry may be lined out with an appropriate notation. The supporting documentation must be retained. INJURIES Medical Treatment (Chapter V, Section F.l, p. 42-43) LAM 024171 Differentiation between medical treatment and first aid should be made in strict compliance with the criteria given. Note in particu lar that certain therapies on the second or subsequent visit, or any prescription medication provided (except a single dose administered on first visit for minor injury or discomfort) are considered to be "medical treatment" and thus the basis for recording such cases (see also F-15, p. 45). Restriction of Work or Motion (Chapter V, Section F.3, p. 43) The operational decisionmaking criteria from the BLS Guidelines are "...Unable to perform all or any part...of the normal assign ment... during all or any part of the workday or shift." Emphasis is on* the employee's inability to "perform all duties normally CAB8909701 * ABS-007351 4 connected with" his or her job (ref. instructions on the OSHA 200). Recordkeeping decisions shall be made in strict compliance with . these criteria. Transfer To Another Job (Chapter V, Section F.4, p. 43) Any change in schedule, or assignment, or any alternative duty including a job-swap, shall be considered a transfer and hence recordable. Distinguishing Injuries From Illnesses (Chapter V, Section D, p. 37-38) Injuries result from a "single instantaneous incident" (0-3, p. 38). Everything else is an illness, and every illness is recordable. ILLNESSES New concepts developed in the BLS Guidelines substantially alter what must be recorded as an occupational illness. While the definition of illness has always included the phrase "any abnormal condition or disor der," BLS now provides additional interpretations in certain areas. Distinguishing Illnesses from Injuries BLS asserts that an "abnormal condition or disorder" that results from anything other than a "single instantaneous incident" is an illness (not an injury) and must be recorded if work exposure is determined to be the cause or contributing factor. Recordkeeping shall be in accord with these criteria. Abnormal Conditions BLS asserts that an illness need not be diagnosed by a physician. Rather, any person qualified by experience or training may "recog nize" a condition. If work exposure is determined to be the cause or contributing factor, the condition must be recorded as an occupa tional illness. Whenever an occupational illness is suspected, "recognized," or discovered by any means, prudent concern for the employee suggests that a physician review the case to confirm that "abnormal condi tions or disorders" do exist (or did exist). If the physician confirms such findings, and if subsequent investigation determines that work exposure is the caus`e or the contributing factor, the case* is recordable. Illness Recording LAM 024172 The instructions on the OSHA 200 log require that information be recorded about every occupational illness. Any report of a suspected occupational CAB8909701 ABS-007352 t 5 illness should trigger appropriate entries on the log sheet in the Illness section (Columns 7-13) within six workdays. If no physician . evaluation is obtained, a "recognized" work-related illness shall remain logged. If a physician's evaluation does not confirm the reported illness condition, the log entry may be lined out. Likewise, an entry may be lined out if investigation reveals no causal or contributory work-related exposures (E.2, p. 40). Preventive transfers to remove an employee from further exposure that may cause an illness are not record able (B-6 and B-7, p. 30). Date of Occurrence for Log Purposes A recordable injury or illness is to be posted to the OSHA 200 log for the year when that injury or illness occurred. Since logs must be maintained for the current year and the previous five years, there may be occasions (particularly for recordable illnesses) when cases will be posted to logs for prior years. For an occupational injury, post the case to the log for the year when the work accident occurred. For an occupational illness, post the case to the log for the year corresponding to (1) the date of initial diagnosis of the illness, or (2) if absence from work occurred before diagnosis, the first day of absence attributable to that illness (ref. instructions on reverse of log sheet and BLS-86 p.9). ' Illnesses Involving Termination or Permanent Transfer For illnesses only, when a termination or permanent transfer is involved, an asterisk (*) is to be placed by the "Type of Illness" checkmark for that case on the log sheet (ref. paragraph preceding A-l, p. 12). Asbestos-Related IIlnesses A common indication of asbestos exposure on a chest x-ray is the pleural plaque, a type of localized scarring of the outer lining of the lungs. The BLS Guidelines consider pleural plaque(s) to be an occupational illness (ref. E-8 and E-9, p. 41). Therefore, a diagnosis of pleural plaque(s) or pleural calcification -or asbestosis or probable asbestosis or any other asbestos-related disease -- is sufficient cause for that case to be recorded on the OSHA 200 log. Placing a checkmark in Column 7b on the log sheet identifies the Type of Illness as "Dust diseases of the lungs" (re. p. 60). Corporate Medical has established protocols for review and evaluation of medical conditions which may be related to asbestos exposure. If asbestos-related disease is confirmed, the OSHA record keeper will be notified of the diagnosis in writing and instructed by Corporate Medical or the consulting physician to log the case. CAB8909701 ABS-007353 LAM 024173