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HTiMIHM E. I. du Pont de Nemours & Company
IMCat#0*ATC0 Wilmington. Delaware 19898
POLYMER PRODUCTS DEPARTMENT
PERSONAL AND CONFIDENriAL
SITE MANAGERS - FOR ACTION
s. S. LORD - BEAUMONT H. F. CANFIELD - CIRCLEVILLE M. R. HARADON - CLINTON R. P. HADEN - FAYETTEVILLE R. D. PRUETT - FLORENCE J. F. GLEITZ - GERMAY PARK W. E. EGAN - LOUISVILLE P. E. OTTO - PENCADER/WB
SITE MANAGERS - FOR INFORMATION
K. L. SZLIGMAN - CHAMBERS WORKS D. B. SCHIEUETZ - GLASGOW R. H. HAHNFELD - HOUSTON
CC : J. C. Besperka/J, W. R. DeGraw J. T. Nolen S. P. Fos ter N. J. Irsch N. C. Jackson R. E. Jackson R. T. Murrill E. E. Woodacre/M.R. Debrunner C. L. Perry, PAD
November 21, 1980
H. L. DEY - PONTCHARTRAIN C. F. RIDDICK - SABINE J. B. SHAFER - SPRUANCE J. A. WILSON - TECUMSEH c. R. DEWEY - TULSA J. C. LEITINGER - WASH. WORKS J. D. SPANGLER - YERKES G. K. WALKER - AKRON
R. D. INGALLS - SENECA W. E. HURST - WAYNESBORO W. D. HOUSEHOLDER - WURTLAND
LOGGING ASBESTOS-RELATED LUNG ABNORMALITIES
The attached communication from N. K. Walters is self-
explanatory and defines an expansion of OSHA logging activity
for cases of benign asymptomatic lung abnormalities which are deemed occupationally related to service with Du Pont. This logging step carries with it the determination of implied Du Pont responsibility for the condition. My purpose in reminding you of this is that we should be sensitive to the _ need to include all appropriate organizations in that decision
making step.
H. E. SERENBETZ ENERGY & ENVIRONMENTAL AFFAIRS MANUFACTURING DIVISION
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E. I. du Pont de Nemours & Company
Wilmington, Delaware 19898
EMPLOYEE RELATIONS DEPARTMENT'
cc: EQC Members
November 19, 1980
RECORDING ASBESTOS-RELATED CONDITIONS ON OSHfflgDRM 200*
f-it'Sl'i 1In light of an intensified medical detection program to identify asbestos-related conditions, additional cases of asbestos related abnormalities and illnesses will probably be revealed.
Safety Fire Protection Guideline 11.1, "Classifying and Reporting Occupational Injuries and Illnesses.", Section 2.3, describes conditions which must be met for tabulating and log ging on OSHA Form 200 (U.S. only) occupational illnesses. In applying this paragraph, all Du Pont work-related instances of asbestos-related abnormalities, whether judged "benign asymp tomatic", "benign symptomatic", or "malignant", should be considered tabulatable and recorded on Form 200 (U.S. only). Tabulating and recording the benign asymptomatic abnormality is a change in practice.
Du Pont's Medical Division does not regard the Benign Asymp tomatic Abnormality as an illness, and thus, our practice has been that of not logging. OSHA, however, maintains that this condition is loggable and has issued citations for failure to log.
The change in logging practice is an administrative procedural change to avoid future citations, and does not reflect a change in Medical Division's position on the significance of the benign asymptomatic condition.
The attached Guidelines "For the Management of Chronic Occupa tional Illnesses" and "For the Diagnosis and Classification of Asbestos - Related Medical Cases", published by the Medical Division are provided as background information materials.
DUP 0962197
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The past practice of submitting Non-Tabulatable G-lOS's for benign asymptomatic asbestos-related cases should be dis continued. Accounting for medical expenses is described in Part 10 of the Service Manual.
Questions on logging and classifying injuries and illnesses should be referred to D. G. Windsor, 774-50S0, or J. I. Weir, 774-2234.
SAFETY FIRE PROTECTION DIVISION
Ned K. Walters, Director Attachments
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TO: DEPARTMENT. HEADS * ' OSH COORDINATORS PRODUCTCON/PLANT MANAGERS LABORATORY-DIRECTORS SAFETY SUPERVISORS: -
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GUIDELINES FOR THE MANAGEMENT OF CHRONIC OCCUPATIONAL ILLNESSES
When a medical examination of an employee or pensioner suggests a chronic illness which might have arisen out of and in the course of Du Pont employment, the site physician and site management should implement the procedure stated below. Medical Division guidelines for specific causal agents should be consulted as appropriate.
1. DIAGNOSIS The site physician should establish the diagnosis and
degree of disability, if any, by a review of all pertinent data and consultation with the Medical Division. The diagnosis and degree of disability should be verified by appropriate medical specialists.
2. CAUSALITY A comprehensive work history for the employee should be
prepared by the site physician and site management and examined -- for a causal agent. Non-Du Pont exposures should also be identified where possible. It is the responsibility of site and departmental management, with advice from the Medical Division and appropriate consultants, to determine causality as promptly as possible,.
This determination and the exposure history should be made a permanent part of the employee's medical record.
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3. EMPLOYEE NOTIFICATION The Du Pont Guidelines to Physicians on Informing Employees
of Abnormal Findings should be followed and the employee or pensioner should be promptly notified of Du Pont's determination of causality. If there is an unavoidable delay in determining causality, employee notification of the known facts should not be postponed. Employee notification should be documented in the medical record.
4. MEDICAL MANAGEMENT AND COSTS If the causality is related to Du Pont employment, and if
a preempting national health plan is not in place, the site should accept the responsibility for costs of appropriate medical' evaluation, follow up, and treatment.
In those cases in which causality has not been determined, site management may choose to assume the costs for appropriate medical evaluation by a medical specialist approved by site management.
If the causality is nOn-Du Pont, the case should be treated as any other non-occupational illness. The employee should be notified as stated above and assisted in seeking and receiving appropriate medical follow up with a private physician.
5. RECORDING REQUIREMENTS A. U.S. - Recording in OSHA Loa An illness with a Du Pont causality should be logged in the OSHA log; an illness with a non-Du Pont causality should not be logged. Regulations require loading within
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six working days of site management's receipt of information that a recordable illness has occurred (i.e., that the diagnosed illness has been determined to be occupationally related). The date of "onset of illness" on the OSHA Form 200 should be the date of medical diagnosis, not the date of determination of causality.
If there is a question as to whether a medical finding constitutes an "illness", the Medical Division should be consulted.
B. Non-U.S. Applicable local regulations for reporting/recording should be determined and a procedure established by Subsidiary management. In the absence of any regulations, a logical recording system should be established in consultation with the Safety and Fire Protection and Medical Divisions.
6. DU PONT S&F TABULATION Tabulation of work-related illnesses for purposes of
Du Pont safety records should follow Safety and Fire Protection Division Guidelines.
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7. EMPLOYEE COMPENSATION When Du Pont causality has been established and disability
exists, site management should promptly assist the employee in
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4 obtaining workers' compensation or other state or federal disability benefits to which the employee may be entitled. Matters of employee compensation should be reviewed with Employee Relations and Legal through normal channels. Site job transfer and pay practices should be followed when an employee is temporarily or permanently placed on another job.
9/13/79
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GUIDELINES FOR THE DIAGNOSIS AND CLASSIFICATION OF ASBESTOS-RELATED MEDICAL CASES
This guideline supplements the Guidelines for the
Management of Chronic Occupational Illnesses (1).
This guideline covers those asbestos-related conditions
listed below. Use of this classification should be restricted to
those cases in which there is evidence of probable asbestos exposure.
Benign Asymptomatic Abnormalities:
Pleural thickening and/or plaques and/or calcification with no evidence of parenchymal disease
Benign Symptomatic Illnesses:
Presumptive asbestosis Confirmed asbestosis Exudative pleural thickening Pleural effusion
Malignant Illnesses:
Mesothelioma of the pleura or peritoneum Carcinoma of the lung, larynx, or gastrointestinal tract (stomach, colon) A presumptive diagnosis of asbestosis is one in which
there is good evidence of parenchymal disease due to asbestos exposure even though there is no interstitial fibrosis noted on
x-ray. Such a case would include pleural x-ray changes, symptoms,
abnormal spirometry and/or abnormal blood gases. Accepted medical practice and NIOSH guidelines' suggest that a confirmed diagnosis
of asbestosis should be made only with the presence of x-ray changes
of interstitial fibrosis, symptoms (dyspnea, cough, etc.), physical
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findings (rales, etc.), impaired pulmonary function (abnormal spirometry or blood gases), and a positive exposure history (2, 3).
A comprehensive history of probable exposure to asbestos and other pulmonary irritants should be obtained by the physician from the patient at the time of the examination. (This history will assist in the determination of causality as well as aiding in the diagnosis.) The history should include all possible pre-Du Pont occupational exposure and off-the-job asbestos-related exposure(4). A detailed evaluation of smoking habits should be made.
A supplemental work history should be prepared by site management listing all periods and/or circumstances of possible asbestos exposure. If the employee was not assigned to a job that involved handling asbestos-containing materials, an attempt should be made to determine whether the employee could have incurred exposure by working near an operation where asbestos dust was released. In determining when and whether causal exposure could have occurred, it should be borne in mind that asbestos-related disorders can result not only from long-term moderate exposure but also from short-term massive exposure.
In all cases where the tentative diagnosis is a benign symptomatic illness or a malignant illness and in other cases if the evaluation is inconclusive, the tentative diagnosis should be discussed with the Medical Division. Where appropriate, the site should 'use an approved medical specialist to carry out the additional testing or evaluation required to establish a diagnosis.
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-3The scope of fuk^her testing will normally be determined by the
specialist, but should include certain minimum tests. A suggested referral letter indicating these tests is attached.
Where an asbestos-related lung abnormality of Du Pont causality has been established, the follow up should at a minimum include a semi-annual posterior-anterior and lateral chest x-ray, and pulmonary function tests. If the employee refuses, this fact should be documented in the employee's medical record.
Those employees with confirmed asbestosis, exudative pleural thickening, pleural effusion or malignant illnesses should be excluded from tasks with potential for exposure to asbestos. Those with benign asymptomatic abnormalities need not be excluded. Those with presumptive asbestosis should be handled on an individual basis.
REFERENCES 1. Medical Division, Du Pont Employee Relations Department,
"Guidelines for Physicians", Section T. 2. Preger, L., et al, "Asbestos-Related Disease", publisher
Grune & Stratton, New York, 1978. 3. NIOSH, "A Guide to the Work-Relatedness of Disease", Rev.
Edicion, January 1979. 4. National Cancer Institute, "Asbestos: An Information
Resource", May 1978.
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DUP 0962205
Dear Dr.
, an employee of the Du Pont ___________, is referred for pulmonary evaluation. Chest x-ray findings have been interpreted as containing some abnormalities.
In your evaluation, the following minimums are requested:
A detailed history of occupational and nonoccupational exposures, including smoking history.
Examination of the lungs.
Review of recent chest x-ray3 that include right and left oblique views.
Complete ventilatory function testing without and with a bronchodilator.
Measurement of arterial blood gases at rest, and after exercise.
A statement of your evaluation of the respiratory impairment, if any.
The etiology of the condition.
Please send your bill for this service (examination, testing, and x-rays) and the report to me.
If the employee requests that a copy of your report be sent to his or her personal physician, please ask that this request be submitted in writing to me. A copy of your report will then be sent from our office.
Please return our x-ray3 by certified mail.
Very truly yours,
DUP 0962206
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Du Pont Safety and Fire Protection Division Guidelines
section ii.i
CLASSIFYING AND REPORTING OCCUPATIONAL INJURIES AND ILLNESSES
CONTENTS
PAGE
Foreword........................................... .... .................................................................. . , l
Definitions.........................................
1
Classification of Injuries.................................. .......................................................... 3
Measuring Injury and Illness Experience...................... ...........................
7
Reporting Injuries and Illnesses.................................................................... ........... 7
OSHA Recording Requirements.....................................
8
Workers' Compensation.....................
9
Alphabetical Index.....................................................
10
APPENDICES
Recordkeeping Requirements Under the Occupational Safety and Health Act of 1970 (Includes OSHA 200 Log)
Report Forms
1. FOREWORD
Du Pom's system for classifying and reporting occupa tional injury and illness experience for worldwide use is based on the requirements of the U.S. Occupational Safety and Health Act of 1970 (OSHA). This system became effective for our recordkeeping and Board of Directors' Safety Award purposes January 1. 1977 and replaced a system based on A.N.S.I. Z16.1. The OSHA based system provides a uniform method for compar ing occupational injury and illness experience world wide among all company sites, as well as all other organizations using a similar system. For some interna tional locations it will be necessary, because of govern
mental requirements, to keep two classifying systems and two sets of records. The OSHA system permits Du Pont to report statistics to the U.S. National Safety Council anJ the U.S. Chemical Manufacturers' Association Experience with this system based on the January. |9"7 Guideline indicates a need for a more consistent approacn to classification within the-com pany This revised Guideline, effective September 1. 1980. clarifies problem areas and points out more clearly the relative need for intensified prevention programs based on the occupational injury and illness
experience of a unit. It is a means of evaluating the effectiveness of the safety activities among all units, departments, and subsidiaries. No changes have been made which would alter classification under the pre
vious Guideline
Du Pom's goal continues to be the elimination of all occupational injuries and illnesses. However, when an accident or illness does occur, the first concern should be to see that the affected employee is given prompt and proper medical treatment and rehabilitation. Only after these priorities have been observed should the classification and record be considered.
2. DEFINITIONS
2.1 Work Environment -- The work environment is comprised of the physical location, equipment, materials processed or used, and the kind of operations performed in the course of an employee's work, whether on or off company premises. Any injury sus tained on company property is considered as occurring in the work environment unless specifically exempted elsewhere in this Guideline.
2.2 Occupational Injury -- Any injury such as a cut. fracture, sprain, amputation, etc., which results from a work related incident or from an exposure involving an incident in the work environment is an occupational injury Conditions resulting from animal bites, such as insect or snake, or from one lime exposure to chemi cals are considered injuries. Also, chemical burns resulting from one time exposure are considered injuries, not illnesses.
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(Rev, 80-08) Section 11 1. Page
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2.3,1 Only illnesses with Du Pont accepted causality are to be tabulated.
2.3.2 Illnesses with the only exposure prior to April 28, 1971 (effective date of OSH A) will not be con sidered tabuiatable but will be logged on the OSHA 200 (L'.S. only) designated as "NT" (Non-Tabulatabie).
2.3.3 A Non-Tab (NT) Lost Workday Case Injury report tG-105) (L'.S. only) will be filed using the date of lust possible exposure to cover possible future legal, medical or workers' compensation costs.
2.3.4 Illnesses with exposure prior to and after April 28. 1971 but latency period not expended from April 28. 1971. will nm be considered tabuiatable but will be logged on the OSHA 200 (U.S. only) designated a "NT". A Non-Tab (NT) Lost Workday Injury report (G-105) will be filed using the date of diagnosis.
2.3.5 Illnesses with exposure after April 28. 1971 and latency period expended will Reconsidered tabulatabie and will be logged (LWC - RWC - MTC). The date of diagnosis will be used on the appropriate form. (If workers' compensation is paid, but no time is lost, an LWC-FaO must be filed - U.S. only).
2.3,7 Occupational illnesses may include, but are not limited to the following categories:
2.3.7 1 Occupational skin diseases or disorders =--
Examples: Contact dermatitis, eczema, or rash caused
by primary irritants and sensitizers or poisonous plants:
oil and chlorocarbon acne; chrome ulcers; chemical
burns or inflammations.
--
2 3 " 2 Dust diseases of the lungs (Pneumoconioses) -- Examples: Silicosis, and asbestosis.
2.3 7 4 Poisoning iswemic effects of toxic materials) -- Examples. Poisoning b> metals, metal fumes, gases, organic solvents, insecticides, or by other chemicals.
2.3 7 5 Disorders due to .physical agents (other than toxic materials) -- Examples: Heatstroke, sunstroke, sunburn, heat exhaustion and other effects of environ mental heat: freezing, frostbite and effects of exposure to low temperatures: caisson disease: effects of ioniz ing radiation (isotopes. X-rays, radium): effects of nonionizing radiation (welding flash, ultra-violet rays, microwaves/
2.3.7.6 Disorders associated with repeated trauma -- Examples: Noise-induced hearing loss; synovitis, tenosynovitis, and bursitis; and other conditions due to repeated motion, vibration, or pressure.
2.3.7.7 Food poisoning - Any illness which is demonstrated to have been caused by tainted food served (sold or given) and ingested on company prop erty is tabuiatable. This excludes edibles brought into the site by employees.
2.3.7.8 Other possible occupational illnesses -- Exam ples: malignant and benign tumors.
2.4 Lott Workday Casa (LWC) - Any work related injury or illness which prevents the employee from reporting to work on any subsequent scheduled shift. (See paragraph 3 for further clarifications).
2.5 Restricted Workday Casa (RWC) -- Any work related injury or illness which prevents the employee from doing any part of his regularly scheduled job on any subsequent scheduled shifts. (See paragraph 3 for further clarification).
2.6 Medical Treatment Casa (MTC) -- Any work related injury or illness which requires treatment by a physician or by registered professional personnel under the standing orders of a physician. (See paragraph 3 for further clarification).
2.7 First Aid Casa (FAC) -- Any work related injury or illness involving one time treatment which does not require a medical professional. (See paragraph 3 for further clarification).
2.8 Employees Special Casas
2.8.1 Temporary or Limited Service Employees (LSE) -- These are people placed on the company roll to pro vide a service on a part-time or temporary basis. They are paid directly by the company and their hours and injuries are to be recorded by the unit in which they are employed.
2.8.2 Loaned Employees (Personnel working at a loca tion other than their own) -- An injury to an employee occurring at a site other than his normal work site is generally charged to the organization with administra tive control of the injured unless the "lender" and "borrower" have established a different agreement prior to any injury Administrative control is con sidered to reside with the organization which exercises control over salaries and other personnel administra tive matters.
Examples of this are employees at locations other than their own for the purpose of providing technical assis tance. Start up assistance, and receiving or providing training. Assignments of this nature are generally ot short duration; usually less than one year. Injuries incurred during travel in such situations are charged to the organization with administrative control of the injured.
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Columns 6 and 13
- INJURIES OR ILLNESSES WITHOUT LOST WORKDAYS. Self-explanatory.
Columns 7a through 7g -- TYPE OF ILLNESS.
Enter a check in only 009 column for each illness.
TERMINATION OR PERMANENT TRANSFER--Place an asterisk to the rignt or the ent^v m columns 7a througn 7g (type of illness) which represented a termination of employment or permanent transfer.
Totals
Ado numoer of entries in columns 1 and 8. Add numoer of cnecxs in columns 2.3.6. 7, 9. 10, and 13. Ado numoer of days m columns 4,5. 11. and 12. Yearly totals for each column 11-13) are reauired for posting. Running or page totals may be generated at tne discretion of tne employer.
if an employee's loss of workdays is continuing at the time the totals are summanzeo. estimate the numoer of future workdays the employee will lose and add mat estimate to me workdays already lost and include this figure m me annual totals. No former entries are to be maoe with resoect to sucn cases m tne next year s log.
Definitions
OCCUPATIONAL INJURY is any injury such as a cut. fracture, scram, amputation, etc., which results from a work accident or from an expo-
The following listing gives tne categories of occupational illnesses and disoraers mat wnl oe utilizes for the purpose of classifying recordable ill nesses For ourooses of information, examples of each category are given, ^ese are tvoicai examoies. however, ano are not to be considered the comoiere '$:ng ot me types ot illnesses and disorders mat are to oe count ec jnoer eacn category.
'a Occupational Skin Diseases or Disorders Examoies Contact aermat.tis. eczema, or rasn caused by on-nary r^rants ano sensitizers or ooisonous oiants. oil acne; enrobe uicers. cnemicai ourns or inflammations, etc.
Dust Diseases of the Lungs (Pneumoconioses) Examoies Silicosis, asoestosis. coal worker s pneumoconiosis, C'.ssmosis. siderosis. ano ctn^*' oneumoconioses.
"c Resoiratory Conditions Due to Toxic Agents Exam^es Sneumcn :.s. pharyngitis, rmnitis or acute congestion a0e to c-'emicais, o-sts. gases, tM^es. tarmef s :ung, etc.
7d. Poisoning (Systemic Effect of Toxic Metenais) Examoies. Poisoning by lead, mercury, cadmium, arsenic, or other metals, poisoning by carbon monoxide, hydrogen sulfide, or other gaes. poisoning by benzol, carbon tetrachloride, or other organic solvents; poisoning by insecticide sorays sucn as oarathion. lead anenate, poisoning by other chemicals sucn as formaldehyde, plastics, and resins, etc.
7e. Disorders Due to Physical Agents (Other than Toxic Materials) Examples: Heatstroke, sunstroke, heat exhaustion, ana otner effects of environmental heat; freezing, frostone. ana eifects of exoosure to low temperatures; caisson disease, effects of ionizing radiation (isotooes. X-rays, radium), effects of nonionizing radia tion (welding flash, ultraviolet rays, microwaves, sunburn), etc.
7f. Disorders Associated With Repeated Traume Examoies. Noise-induced hearing loss; synovitis, tenosynovitis, and bursitis. Raynaud's onenomena. ano other conditions due to repeated motion, vibration, or pressure.
7g. All Other Occupational Illnesses Examoies. Anthrax, brucellosis, infectious heoatitis. malignant and benign tumors, food poisoning, histoplasmosis, coccidioido mycosis. etc.
MEDICAL TREATMENT includes treatment (other than first aid) admin istered by a physician or by registered professional personnel unoer trie standing orders of a ohysician. Medical treatment does NOT include firstaid treatment (one-time treatment and su&seouent ooservation of minor scratches, cuts, burns, solmters, and so forth, which 00 not ordinarily re quire medical care) even though provided by a physician or registered professional personnel.
ESTABLISHMENT: A single physical location wnere business is conduct ed or wnere services or industrial operations are performed (for example a factory, mill, store, hotel, restaurant, movie theater, farm, ranch, bank, sales office, warehouse, or central administrative office). Where distinctly separate activities are pertormea at a single pnysicai location sucn as con struction activities ooerateo from tne same physical location as a tumoer yard, each activity shall be treated as a separate establishment.
For firms engaged m activities which may be onvsicaily disoersed^suEfi as agriculture, construction, transportation; communications, and eiectric. gas, and sanitary services, records may be maintained at a oiace to wmen employees report eacn day.
Records *or oersonnel wno do not primarily report or work at a smgie establishment, such as traveling salesmen, technicians, engineers, etc., snail oe maintained at the location from wmen they are paid or tne case from wnicn personnel ooerate to carry out their activities.
WORK ENVIRONMENT is comor*seo of The onysicaf location eouioment materials processed or jsea. anc the Kinds o* operations oertormea *n me course of an employee s worn, wnetner on or off the emoiover s premises
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Bureau of laDor Statistics
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Columns 6 nd 13
- INJURIES OR ILLNESSES WITHOUT LOST WORKDAYS. Sell-explanatory.
Columns 7a through 7g - TYPE OF ILLNESS.
Enter a check in only on* column tor each illness.
TERMINATION OR PERMANENT TRANSFER--Place an asterisk to the right of the entry in columns 7a through 7g (type of illness) which reoresenteo a termination of employment or permanent transfer.
Totals
Add numoer of entries in columns 1 and 8.
Add numoer of cnecxs in columns 2. 3. 6. 7, 9. 10, and 13.
Add numoer of days in columns 4, 5, 11. and 12.
_
Yearly totals for each column 11-13) are required for posting. Running or
page totals may ee generated at the discretion of the employer.
If an employee's loss of workdays is continuing at the time the totals are summarized, estimate the numoer of future workdays the employee will lose and add that estimate to the workdays already lost and include this figure m the annual totals No further entries are to be made with respect to sucn cases in the next year's log.
Definitions ^OCCUPATIONAL INJURY is any iniury such as a cut, fracture, sprain,
amoutation, etc., which results from a work accident or from an expo sure involving a single incident in the work environment. NOTE: Conditions resulting from animal bites, such as insect or snake bites or from one-time exposure to cnemicais. are considered to be miuries.
OCCUPATIONAL ILLNESS of an employee is any abnormal condition or pisoroer, otner than one resulting from an occupational injury, caused by exposure to environmental factors associated with employment. It in cludes acute and chronic illnesses or diseases which may be caused bv in halation, aDSorotion, ingestion, or direct contact.
The following listing gives the categories of occupational illnesses and dis orders that will pe utilized for the puroose of classifying recordaole ill nesses. ror ourooses of information, examples of each category are given. vnese are tvoical examples, however, and are not to be considered the comce'e listing of the tvoes of illnesses and disoroers that are to be count ed unaer each category.
Ta Occupational Skin Dittoes or Disorders Examples Contact oermauus. eczema, or rash caused bv pri mary rritants and sensitizers or poisonous plants, oil acne. Chrome ulcers, cnemicai burns or inflammations, etc.
'S Dust Diseases of the Lungs (PneumoeoniosesI Examples Silicosis, asoestosis, coal workers pneumoconiosis, Pvssinosis. siderosis. and ctne- pneumoconioses.
?c Respiratory Conditions Due to Toxic Agents Examples Pneumonitis, pna-yngitis, minms or acute congestion due tc Chemicals, ousts, gases, or fumes, farmer s lung. etc.
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7d. Poisoning (Systemic Effect of Toxic Materials} Examples: Poisoning by lead, mercury, cadmium, arsenic, or other metals, poisoning bv carbon monoxide, hydrogen suifide, or other gaaes. poisoning by benzol, carbon tetrachloride, or other organic solvents: poisoning by insecticide sorays such as parathion. lead arsenate; poisoning bv otner chemicals sucn as formaldehyde, plastics, and resins; etc.
7e. Oisordan Out to Physical Agents (Other than Toxic Materials) Examples: Heatstroke, sunstroke, heat exnaustion, and other effects of environmental heat, freezing, frostbite, and effects of exposure to low temperatures; caisson disease; effects of ionizing radiation (isotooes. X*ravs, radium), effects of nonionizing radia* tion (welding flasn. ultraviolet rays, microwaves, sunburn), etc.
7f. Disorders Associated With Reoeated Trauma Examples: Noise*mduced hearing loss; synovitis, tenosynovitis, and bursitis; Raynaud's pnenomena. and other conditions due to reoeated motion, vibration, or pressure.
7g. All Other Occupational Illnesses Examples. Anthrax, oruceiiosis. infectious heoatitis. malignant and benign tumors, food ooisonmg. htstoolasmosis. coccidioido* mycosis, etc.
MEDICAL TREATMENT includes treatment (other than first aid) admin* istereo bv a physician or by registered professional personnel under the standing orders of a physician. Medical treatment dots NOT include first* aid treatment (one-time treatment and subseouent ooservation of minor scratches, cuts, burns, solinters. and so forth, which oo not ordinarily re* quire medical care) even though provided bv a physician or registered professional personnel.
ESTABLISHMENT: A single physical location where business is conduct* ed or wnere services or industrial operations are performed (for examoie: a factory, mill, store, hotel, restaurant, movie tneater. farm, ranch, bank, sales office, warehouse, or central administrative office). Where distinctly separate activities are performed at a single onysicai location.such as con struction activities ooerated from tne same onysicai location as a lumber vara, eacn activity snail be treated as a separate estaohsnment
For firms engaged in activities wnch may oe onysicaiiy dispersed rkicn as agriculture, construction, transportation, communications, and electric, gas. ana sanitary services, records may be maintained at a oiace to wmen employees report eacn day.
Records for personnel who do not primarily report or work at a single estabitsnmem. sucn as traveling salesmen, tecnmcians. engineers, etc., snail be maintained at tne location from wnich they are paid or the base from which personnel ooerate to carry out tneir activities.
WORK ENVIRONMENT is comprised of the physical location equipment, materials orocessed or used, ana tne xmos of operations performed >n tne course of an employee s worn, wnetner on or o'* tne employer $ premises.
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Help in formulating effective preventive measures through an objective analysis of injury or illness causes.
Pinpoint injury and illness trends^and patterns.
Permit performance evaluation. '
A report should be written in a clear, concise style so that anyone unfamiliar with the accident site and workconditions can readily understand what happened, the circumstances involved and the conclusions reached. Photographs, sketches and copies of special rules or instructions which might clarify the incident further or which are referred to in the report should be enclosed. Report facts, not conjectures.
5.2 Reports To Be Submitted and When -- Reports of fatalities, lost workday and restricted work^ day cases are to be submitted to the Safety and Fire Protection Division. Employee Relations Department. Wilmington. Delaware. These reports are to be signed by the plant manager, laboratory director, field project manager, warehouse supervisor or person in charge of the reporting unit.
5.2.1 Fatality and Lost Workday Cases (LWC) --
A. Brief summary by wire or telephone within 24 hours of the incident.
B, Detailed report, in duplicate on Form G-105, with in one week. To establish a Personal Injury (P.I.) number for form G-105, follow the sequence of numbers to match the sequence of dates. If more than one person is injured in a single incident, con tinue to use the established pattern followed by let ters of the alphabet. (Example: 1-A. I-B. 1-C). Use fractional numbers if it is necessary to issue a report for a case which occurred prior to a case already reported so that the sequence of numbers matches the sequence of dates (Example: 1-1/2. 1-1/4, 1-1/8. etc.)
C Final injury report (U.S. only), in duplicate on Form G -108. when costs are known and the case is considered closed.
D If additional details develop, a corrected report should be submitted.
5 2 2 Restricted Workday Cases (RWC) -- Detailed report, single copy, on form G-l 11 within at least.two weeks oi incident To establish an RWC number, follow same rules as stated for Lost Workday Cases.
5 2,3 Monthly Summary -- One copy on Form G-l 10 'US only) and by telex (International Units) due before fifth calendar day of succeeding month (data to include injury and illness experience of calendar month i
5 2 4 Guideline and Report Copies - Extra copies of this Guideline may be obtained by sending a Stationery
& Forms Requisition (Form G-352) to the General Services Department, Wilmington. Delaware. This order form can also be used to obtain the following company accident and illness reports: Lost Workday (G-105), Restricted Workday (G-l 11). Medical Treat ment (G-l 13), Monthly Safety Record Summary (G110).
Basic recordkeeping concepts and guidelines are included with instructions on the back of form OSHA No. 200. (APPENDIX A). These paragraphs summar ize the major recordkeeping concepts and provide addi tional information to aid in keeping records accurately. 6.1 Posting Requirements -- From February 1 to March 1, each establishment must post in areas where notices to employees are customarily posted, a copy of the year's totals and information following the fold line of the last page of form OSHA No. 200. An OSHA No. 200 with only the yearly totals, establishment iden tification, and certification may be used for this pur pose. Establishments having no injuries or illnesses during the year must enter zeros on the total line and post the form. The person responsible for the annual summary totals shall certify that the totals are true and sign the form.
6.2 The Occupational Injuries and Illnesses Annual Survey Form 200S -- The form will be mailed to each unit selected to participate in the Bureau of Labor Statistics' Annual Survey of Occupational Injuries and Illnesses. Upon receipt, the unit shall promptly complete and return the form in accordance with the instructions. 6.3 Record Maintenance, Retention, and Access
All recordkeeping forms (current and retained) must be available at ihe establishment for inspection and copying by representatives of the Department of Labor, the Department of Health and Human Services, or States accorded jurisdiction under the act. The log, form OSHA No. 200. shall upon request, be made available to any employee, former employee, and to their representatives for examinations and copying in a reasonable manner and at reasonable times. Access to the log shall be for any establishment in which the employee is or has oeen employed and covers all logs
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required to be maintained or retained by the company.
OSHA forms can be obtained from Regional or Area
OSHA Offices (See addresses and telephone numbers
in the first appendix (Recordkeeping Requirements
under the Occupational Safety and Health Act of
1970).
_
6.4 Annual Summary of Injuries and Illnesses (OSHA-200S) -- One copy sent to Safety & Fire Pro tection Division and one copy posted at unit site by February I.
7. WORKERS' COMPENSATION (Applicable
to U.S. Sites only.) -- Injury and illness classification
under Du Pont guidelines is entirely independent of worker's compensation laws.
Because there will be alleged cases and cases judged compensable by state workers' compensation agencies, use of For Accounting Only (FAO) and Non-Tabuiatable (NT) reports will be necessary on Form G-105 Lost Workday Cases.
Forms necessary for reporting to local state worker s compensation agencies can be obtained from local state agencies.
Details on compensability are covered in Part 10 of the E. I. du Pont de Nemours and Company Service Manual.
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