I reduced my LTCF but my TRIF didn’t change why

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# NON-MANDATORY APPENDIX A TO SUBPART B-PARTIALLY EXEMPT INDUSTRIES (cont.) ## 71-306. Determination of new cases. (cont.) (2) When an employee experiences the signs or symptoms of an injury or illness as a result of an event or exposure in the workplace, such as an episode of occupational asthma, must I treat the episode as a new case? Yes, because the episode or recurrence was caused by an event or exposure in the workplace, the incident must be treated as a new case. (3) May I rely on a physician or other licensed health care professional to determine whether a case is a new case or a recurrence of an old case? You are not required to seek the advice of a physician or other licensed health care professional. However, if you do seek such advice, you must follow the physician or other licensed health care professional's recommendation about whether the case is a new case or a recurrence. If you receive recommendations from two or more physicians or other licensed health care professionals, you must make a decision as to which recommendation is the most authoritative (best documented, best reasoned, or most authoritative), and record the case based upon that recommendation. (Cross Reference: 1904.6) HISTORY: Amended by State Register Volume 26, Issue No. 6, Part 2, eff June 28, 2002; SCSR 42-5 Doc. No. 4802, eff May 25, 2018; SCSR 44-6 Doc. No. 4893, eff June 26, 2020. ## 71-307. General recording criteria. (a) Basic requirement. You must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. You must also consider a case to meet the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted w…

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# INSPECTION PROCEDURES (cont.) such records exist and are maintained). It will be left to the discretion of the Area Director or the CSHO as to whether OSHA-300 and 301 data should also be recorded for any of the subcontractors. 6. Federal Agencies. - Federal agency injury and illness recording and reporting requirements shall comply with the requirements under § 1904, subparts C, D, E, and G, except that the definition of "establishment" found in § 1960.2(h) will remain applicable to federal agencies. B. Recording Criteria. - Employers must record new work-related injuries and illnesses that meet one or more of the general recording criteria or meet the recording criteria for specific types of conditions. 1. Death; 2. Days Away from Work; 3. Restricted Work; 4. Transfer to another job; 5. Medical treatment beyond first aid; 6. Loss of consciousness; 7. Diagnosis of a significant injury or illness; or 8. Meet the recording criteria for Specific Cases noted in $1904.8 through § $1904.11. C. Recordkeeping Deficiencies. 1. If recordkeeping deficiencies are suspected, the CSHO and the Area Director or designee can request assistance from the Regional Recordkeeping Coordinator. If there is evidence that the deficiencies or inaccuracies in the employer's records impair the ability to assess hazards, injuries and/or illnesses at the workplace, a comprehensive records review shall be performed. 2. Other information related to this topic: a. See CPL 02-00-135, Recordkeeping Policies and Procedures Manual, December 30, 2004, and CPL 02-02-072, Rules of Agency Practice and Procedure concerning OSHA Access to Employee Medical Records, August 22, 2007. b. Other OSHA programs and records will be reviewed, including hazard communication, lockout/tagout, emergency evacuation and personal protective equipment. Additional programs will be reviewed as necessary. c. Many standard-specific directives provide additional instruction to CSHOs request…

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# COMPLIANCE GUIDELINES AND RECOMMENDATIONS FOR PROCESS SAFETY MANAGEMENT (NON-MANDATORY) (cont.) ## 12. "Investigation of Incidents." (cont.) Employers need to develop in-house capability to investigate incidents that occur in their facilities. A team needs to be assembled by the employer and trained in the techniques of investigation including how to conduct interviews of witnesses, needed documentation and report writing. A multi-disciplinary team is better able to gather the facts of the event and to analyze them and develop plausible scenarios as to what happened, and why. Team members should be selected on the basis of their training, knowledge and ability to contribute to a team effort to fully investigate the incident. Employees in the process area where the incident occurred should be consulted, interviewed or made a member of the team. Their knowledge of the events form a significant set of facts about the incident which occurred. The report, its findings and recommendations are to be shared with those who can benefit from the information. The cooperation of employees is essential to an effective incident investigation. The focus of the investigation should be to obtain facts, and not to place blame. The team and the investigation process should clearly deal with all involved individuals in a fair, open and consistent manner. ## 13. "Emergency Preparedness." Each employer must address what actions employees are to take when there is an unwanted release of highly hazardous chemicals. Emergency preparedness or the employer's tertiary (third) lines of defense are those that will be relied on along with the secondary lines of defense when the primary lines of defense which are used to prevent an unwanted release fail to stop the release. Employers will need to decide if they want employees to handle and stop small or minor incidental releases. Whether they wish to mobilize the available resources at the plant and have them brought to bear on a more signifi…

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# IMMINENT DANGER, FATALITY, CATASTROPHE, AND EMERGENCY RESPONSE (cont.) sooner a witness is interviewed, the more accurate and candid the witness statement will be. b. If an employee representative is involved in the inspection, he or she can serve as a valuable resource by helping to identify employees who might have information relevant to the investigation. c. Conduct employee interviews privately, outside the presence of the employer. Employees are not required to inform their employer that they provided a statement to OSHA. d. When interviewing: - Properly document the contact information of all parties because follow-up interviews with a witness are sometimes necessary. - When appropriate, reduce interviews to writing and have the witness sign the document. Transcribe video and audio recorded interviews and have the witness sign the transcription. - Read the statement to the witness and attempt to obtain agreement. Note any witnesses' refusal to sign or initial his/her statement. - Ask the interviewee to initial any changes or corrections made to his/her statement. - Advise interviewee of OSHA whistleblower protections. e. See Chapter 3, Inspection Procedures, for more information on conducting interviews. 2. Informer's Privilege. a. The informer's privilege allows the government to withhold the identity of individuals who provide information about the violation of laws, including OSHA rules and regulations. The identity of witnesses will remain confidential to the extent possible. However, inform each witness that disclosure of his/her identity may be necessary in connection with enforcement or court actions. b. The informer's privilege also protects the contents of statements to the extent that disclosure would reveal the witness' identity. When the contents of a statement will not disclose the identity of the informant (i.e., statements that do not reveal the witness' job title, work area, job duties, or other information that …

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# COMPLIANCE GUIDELINES AND RECOMMENDATIONS FOR PROCESS SAFETY MANAGEMENT (NON-MANDATORY) (cont.) ## 6. "Employee Training." (cont.) Hands-on-training where employees are able to use their senses beyond listening, will enhance learning. For example, operating personnel, who will work in a control room or at control panels, would benefit by being trained at a simulated control panel or panels. Upset conditions of various types could be displayed on the simulator, and then the employee could go through the proper operating procedures to bring the simulator panel back to the normal operating parameters. A training environment could be created to help the trainee feel the full reality of the situation but, of course, under controlled conditions. This realistic type of training can be very effective in teaching employees correct procedures while allowing them to also see the consequences of what might happens if they do not follow established operating procedures. Other training techniques using videos or on-the-job training can also be very effective for teaching other job tasks, duties, or other important information. An effective training program will allow the employee to fully participate in the training process and to practice their skill or knowledge. Employers need to periodically evaluate their training programs to see if the necessary skills, knowledge, and routines are being properly understood and implemented by their trained employees. The means or methods for evaluating the training should be developed along with the training program goals and objectives. Training program evaluation will help employers to determine the amount of training their employees understood, and whether the desired results were obtained. If, after the evaluation, it appears that the trained employees are not at the level of knowledge and skill that was expected, the employer will need to revise the training program, provide retraining, or provide more frequent refresher training se…

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$12-60-50 timely and appropriate responses to correct these conditions. (viii) Provide a mechanism to investigate accidents and "near miss" incidents, so that the root cause and means for preventing a recurrence are identified. For the purposes of this section, the term "accident" means any unexpected happening that interrupts the work sequence or process and that may result in injury, illness, or property damage. (ix) Provide a means to review injury and illness trends over time, so that patterns with common causes are identified and eliminated. (x) Establish a mechanism for the employer to conduct ongoing, periodic in-house safety and health inspections so that new or previously missed hazards or failures in controls are identified. Inspections shall be conducted with a frequency necessary to be effective. (xi) Address the impact of emergency situations and develop written plans and procedures to insure employee safety during emergencies. For the purpose of this section, the term "emergency situation" means an unforeseen single event or combination of events that calls for immediate action to prevent, control or contain injury or illness to person or damage to property. (xii) Establish procedures for transmitting and enforcing safe 60-5

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) management of change provisions. In addition, the management of change procedures are used to insure that the equipment and procedures are returned to their original or designed conditions at the end of the temporary change. Proper documentation and review of these changes is invaluable in assuring that the safety and health considerations are being incorporated into the operating procedures and the process. - Employers may wish to develop a form or clearance sheet to facilitate the processing of changes through the management of change procedures. A typical change form may include a description and the purpose of the change, the technical basis for the change, safety and health considerations, documentation of changes for the operating procedures, maintenance procedures, inspection and testing, P&IDs, electrical classification, training and communications, pre-startup inspection, duration if a temporary change, approvals and authorization. Where the impact of the change is minor and well understood, a check list reviewed by an authorized person with proper communication to others who are affected may be sufficient. However, for a more complex or significant design change, a hazard evaluation procedure with approvals by operations, maintenance, and safety departments may be appropriate. Changes in documents such as P&IDs, raw materials, operating procedures, mechanical integrity programs, electrical classifications, etc., need to be noted so that these revisions can be made permanent when the drawings and procedure manuals are updated. Copies of process changes need to be kept in an accessible location to ensure that design changes are available to operating personnel as well as to PHA team members when a PHA is being done or one is being updated. 12. Investigation of Incidents. Incide…