Safety Lines

The Newsletter of Minnesota OSHA
Number 51 Spring 2006

Excavation, trenching: dig ing-in to OSHA regulations g By Diane Amell, MNOSHA Training Officer
Excavation and trenching are among the most hazardous of construction operations. In 2005, Minnesota OSHA (MNOSHA) investigated four accidents involving excavation work that resulted in death or serious injury. The requirement that employees in an excavation "shall be protected from cave-ins by an adequate protective system," 1926.652(a)(1), was among the top 10 most cited standards by MNOSHA in the construction industry during 2005. What do MNOSHA investigators (OSHIs) look for when inspecting an excavation site? In general, the OSHI has these objectives on a jobsite: • determine whether the protective system in use is adequate, in good repair and not in danger of failure; • verify that sloping, where used, is at least 1.5:1; • identify the basis that the employer used to determine the proper employee protection system (e.g., proper sloping, bracing); • check around the edges of the trench to assure the spoil pile and any tools or equipment are at least two feet away or are otherwise prevented from falling on the employees working below; • interview employees to establish their level of training and how the proper use of sloping or the protective system is enforced; • identify key personnel, such as the competent person on site or the registered professional engineer who designed the system;

Above: Employees working in an excavation moments before a cavein. Below: The same excavation after the cave-in. The employees evacuated the trench prior to the mud slide. No one was hurt.

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• determine whether periodic inspections are being performed; • evaluate the effectiveness of employee training and inspection procedures, including the corrections taken after any accidents or near misses; and • identify other apparent violations. One of the excavation issues where there is often confusion is what makes someone a "competent person." A competent person is someone who: • has had training and is knowledgeable about soils analysis, the use of protective systems and the requirements of the excavation standard; • is capable of identifying existing and predictable hazards in excavation work; and • has the authority to take prompt measures to abate these hazards.

Most frequently cited standards in excavation and trenching, 2001 through 2005
Standard 1926.652(a)(1) 1926.651(c)(2) 1926.651(j)(2) 1926.651(k)(1) Description Use of sloping or protective systems Means of egress Protection from material falling or rolling into the excavation Inspections of excavation operations by a competent person Total 295 107 100 99

Other issues the OSHI will address on-site include: • which aspects of the employee protection program were designed or approved by a registered professional engineer; • whether there is a safe means of egress from the excavation; • whether any underground utility installations are properly protected, supported or removed; • whether surface encumbrances, such as trees, rocks or pavement, have been removed or supported to safeguard employees (this includes protection of the employees working above the excavation, as well as those down in it);
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• whether a hazardous atmosphere can develop within the excavation and, if so, that air quality tests are conducted, there is emergency rescue equipment on-site and the employer is in compliance with other requirements specified in Minnesota Rules 5207.0300-.304 Confined Spaces; • whether employees are working under loads handled by lifting or digging equipment, in violation of the standard; and • whether an adequate warning system is in place and operational whenever mobile equipment is used near the excavation. In addition to 29 CFR 1926 Subpart P, excavators must be in compliance with Minnesota Rules 5207.1000 Operation of Mobile Earth-Moving Equipment. This standard requires employees operating or working near mobile equipment receive training and wear high-visibility garments, such as vests. The standard also requires such equipment be equipped with back-up alarms or that a signal person be used. Headlights and rear lights must be used in low-light conditions. Visit, the federal OSHA Trenching and Excavation topics page, for more information.


The Construction Health And Safety Excellence (CHASE) Minnesota program is a major safety initiative implemented by the Department of Labor and Industry in 2003 to reduce the number of injuries, illnesses and fatalities at participant construction industry employers. The partnership charter acknowledges the importance of providing a safe, healthful work environment in construction and seeks a working relationship that creates mutual trust and respect among all parties, including project owners and construction workers, involved in the construction process. Certificates of achievement were presented to participant employers Jan. 19, during an Associated General Contractors (AGC) of Minnesota breakfast event in St. Paul, Minn.

Above (l to r): Tyrone Taylor and Jeff Isakson, Minnesota OSHA; Chris Tschida, M.A. Mortenson Company, Minneapolis; Don Rachel, Rachel Contracting, LLC, Blaine, Minn.; and Bruce W. Engelsma, Kraus-Anderson Construction Co., Minneapolis.

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Spring 2006

Lockout/tagout Q&A: frequently answered questions
By James Krueger, OSHA Management Team Director

Minnesota OSHA (MNOSHA) Compliance often receives calls for interpretations of standard 29 CFR 1910.147, the control of hazardous energy (lockout/tagout). Below are answers to several of the most frequently asked questions. some unique, custom equipment Q We have designed and manufactured to our that was specifications. Does each piece of equipment require a specific procedure?

A MNOSHAisbelieves a specific, documented procedure necessary in most energy control
situations, because of the number of variables involved in controlling hazardous energy and the need for authorized employees to carefully follow the sequential steps in the energy control procedure. However, employers are not necessarily required to develop a separate procedure for every machine or piece of equipment. In appropriate situations, similar machines or pieces of equipment (i.e., those having the same type and magnitude of stored energy), which have the same or substantially similar types of controls, can be covered with a single procedure. A common procedure must include a method of identification (e.g., by type, location or model number) that ensures an authorized employee can determine which energy control procedure applies to a particular machine or piece of equipment.

control procedures. MNOSHA interprets this to mean that each energy control procedure must be inspected at least annually. In addition, MNOSHA agrees that a separate procedure does not have to be developed for each and every machine or piece of equipment, and that a comprehensive (generic) energy control procedure, with supplemental checklists or appendices, may very well address the steps necessary to perform servicing and maintenance work safely. Such a procedure would not have to be repeated on every applicable machine. However, MNOSHA believes there are also situations that require a unique energy control procedure to deal with the servicing and maintenance hazards.
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Q We understand the machine-specific lockout procedures need to be reviewed annually. Does
an audit of every procedure need to be performed annually for compliance?

A Under the requirements of paragraph to 1910.147(c)(6)(i), the employer is required
conduct a periodic inspection of the energy
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MNOSHA will carefully examine the energy control procedure of any employer who claims that only one comprehensive procedure is necessary to ensure the single procedure is, indeed, adequate. The goal of any procedure is to ensure it does not become so complex that service and maintenance employees cannot easily follow it. To qualify as one procedure, the supplemental checklists or appendices must support the comprehensive energy control procedures by having the same: 1. intended uses for different machines or equipment; 2. procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy; 3. procedural steps for the placement, removal and transfer of lockout or tagout devices, and the responsibility for each of them; and 4. requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices and other energy control measures. The annual inspection required to be performed on an energy control procedure is intended to ensure: • the procedure is being followed; • the employees involved know their responsibilities under the procedure; • the procedure provides the necessary protection, with respect to servicing and maintenance activities; and • any needed changes are identified.

of stored energy could cause injury to employees. MNOSHA interprets this to cover any machinery that may cause injury. In addition, 1910.147(c)(1) states the employer is required to establish an energy control program, which includes procedures, training and periodic inspections, before an employee performs any servicing or maintenance activity where there may be exposure to injury from hazardous energy. This paragraph, as well as 1910.147(d)(3), further stipulates the machine or piece of equipment must be isolated from the energy source and rendered inoperative prior to performing such work, including emergency servicing and maintenance operations. is trained on Q Does each employee who procedures need to machine-specific lockout be audited for their compliance annually, and can auditing be accomplished by using a representative number of people and procedures? The employee A inspection doesperforming the periodic not have to observe every authorized employee implementing the energy control procedure on every machine on which he or she is authorized to perform servicing and maintenance to meet the review requirements under paragraph 1910.147(c)(6)(i)(C) and (D). The inspector participating in the review needs to observe a representative number of such employees implementing the procedure and talk with all other authorized employees, even though they may not be implementing an energy control procedure. This review may be completed in one or more meetings in which all authorized employees will be in attendance to review the specific energy control procedures. MNOSHA believes these reviews, which will need to be performed during the periodic inspections, will assure employees follow and maintain proficiency in
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Q Does the requirement for written, machinespecific lockout procedures apply to the
manufacture and assembly of custom machines that are not permanently housed in the facility? These machines are assembled and tested in the facility, then shipped to an end user.

A Under 1910.147(a)(1)(i), the scope of the standard covers all equipment in which the
“unexpected” energization, start up or release
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the energy control procedure and the inspector will be better able to determine whether changes are needed. MNOSHA does not believe that, by itself, “annual refresher training” for all authorized employees, even if it includes a review of lockout/tagout responsibilities for each authorized employee, satisfies the periodic inspection review requirements of paragraph 1910.147(c)(6)(i)(C) and (D). This is because certain benefits are expected to be derived from the talks with individual employees that may not be achieved in group training. Some of the advantages include: identifying energy control procedure deficiencies, misinterpretation and deviations; evaluating task proficiency of the authorized employees; providing immediate feedback regarding procedure implementation; and assessing the need for specific retraining. Group training sessions can be an effective way of partially accomplishing the periodic inspection reviews, during which employee knowledge of the hazards and the necessity for the protective procedures is reinforced. Employees must recognize they need to follow the procedures carefully to ensure the safety of all. Other review methods include random audits, planned visual observations and modified plant safety tours. Under paragraph 1910.147(c)(7)(iii)(A), retraining must be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard or when there is a change in the energy control procedure. MNOSHA will continue to evaluate periodic inspection protocols to ensure all energy control procedures are inspected and that each involved employee has an opportunity to review his or her energy control procedure responsibilities. For further assistance, please contact any MNOSHA area office.

MNOSHA area offices
St. Paul (651) 284-5050 1-800-342-5354 Duluth (218) 733-7380 Mankato (507) 389-6507

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Spring 2006

Minnesota Safety Report
By Brian Zaidman, Research Analyst Research and Statistics

Research highlights:

The number of workplace injuries and illnesses continued to decline during 2004. The latest occupational injury and illness figures show there were an estimated 105,500 recordable injury and illness cases in 2004; about 28,700 cases involved one or more days away from work. The comparable figures for 2003 were 111,600 total cases and 29,900 days-away-from-work cases. There were 80 workrelated fatalities in 2004, up from 72 in 2003, but below the 81 fatalities that occurred in 2002. Later this spring, the Department of Labor and Industry will release its annual Minnesota Workplace Safety Report, detailing injury and illness rates and workplace fatalities for 2004. The report is based on the U.S. Bureau of Labor Statistics’ Survey of Occupational Injuries and Illnesses and Census of Fatal Occupational Injuries (CFOI) and on OSHA activity reports. The report will be available online at Following are the major highlights from that report.
Nonfatal occupational injuries and illnesses

• Minnesota’s total rate of workplace injuries and illnesses was 5.3 cases per 100 full-time-equivalent (FTE) workers in 2004. This represents a 4 percent decrease from the 2003 rate of 5.5 cases per 100 FTE workers. • The rate of cases with days away from work (the most severely injured workers) was 1.5 per 100 FTE workers in 2004 and 2003. • Minnesota’s industry sectors with the highest total injury and illness rates per 100 FTE workers were: 1. construction (8.6); 2. agriculture, forestry, fishing and hunting (8.6); and 3. transportation and warehousing (7.6). • Four of the 10 industry subsectors with the highest total case rates were in private-sector and publicsector health care and social assistance. • The industry subsectors with the highest numbers of cases with days away from work were specialty trade contractors (1,970 cases) and private-sector nursing homes (1,800 cases). The top 10 industry groups accounted for 12,510 days-away-from-work cases, 44 percent of the total. Additional statistics about the characteristics of the injured workers, the characteristics of their injuries and the amount of time away from work are available for cases with days away from work. • Sprains and strains accounted for 43 percent of the cases with days away from work. The secondhighest category was soreness and pain, with 10 percent of the cases. • The back and lower extremities were the most commonly injured body parts, accounting for nearly half the cases. Safety report, continues ...
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• Overexertion – often while lifting people or objects, falls and contact with objects and equipment were the most common injury events. • "Floors and ground surfaces" was the most frequent source of injury category, followed by the injured worker’s own motion or bodily position.
Fatal occupational injuries

The CFOI covers all fatal work injuries in the private and public sectors, regardless of program coverage; thus, it includes federal workers and self-employed workers, along with all others. However, fatal illnesses (such as asbestosis) are excluded. • In 2004, 80 Minnesotans were fatally injured on the job. For 2000 through 2004, Minnesota had an average of 75 fatal work injuries a year, consisting of approximately 59 wage-and-salary workers and 17 self-employed people. • Among industry sectors, agriculture, forestry, fishing and hunting recorded the highest number of 2004 worker fatalities, with 19. Construction, with 16 cases, had the second-highest number of fatalities. • The most frequent causes of Minnesota’s fatal work injuries for 2004 were: highway transportation accidents (36 percent); contact with objects and equipment (23 percent); falls to a lower level (14 percent); and assaults (14 percent).
Minnesota OSHA activities

During federal fiscal-year 2005 (October 2004 through September 2005), Minnesota OSHA: • conducted nearly 2,600 compliance inspections affecting the workplaces of 128,000 workers; • found violations resulting in the assessment of more than $4 million in penalties; • conducted nearly 1,000 worksite consultations, affecting the workplaces of 73,000 workers, and helped employers avoid more than $4 million in penalties; and • provided 98 safety and health seminars, plus many other safety presentations and on-site training visits.

Coming soon to a site near you: crane-operator regulation
Effective July 1, 2007, no individual may operate a crane, with the lifting capacity of five tons or more, on a construction site unless that person has a valid crane-operator certificate. The certificate must be issued by a nationally recognized and accredited certification program. For more information, see New crane-operator regulations – an overview (page 6) in the Winter 2006 edition of Safety Lines, available online at

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Spring 2006

Guthrie Theater worksite: Construction safety show takes curtain call

Above: DLI Commissioner Scott Brener and Assistant Commissioner Roslyn Wade joined Andy Smoka, MNOSHA Workplace Safety Consultation, and Brock Kiecker, McGough, on a walk-through of the Guthrie on the River Theater site in Minneapolis. The tour included many views to remember, because the site overlooks the city and the Mississippi River.

Construction of the new Guthrie on the River Theater has been completed, ending the monthly safety and health visits by MNOSHA Workplace Safety Consultation (WSC). Most of the construction work was completed by mid-February and the theater will open this summer. At its peak, 271 workers were on-site each day. During the project’s 28 months, WSC visited the site 20 times. The results were six recordable injuries and no lost-time claims for approximately 750,000 total construction work hours.

Career opportunities

The Minnesota Occupational Safety and Health (MNOSHA) program, administered by the Minnesota Department of Labor and Industry, was established by the Minnesota Legislature in 1973. Working for MNOSHA can be a very rewarding job. Minnesota’s economy has a great variety of industries and its business leaders are often at the forefront of new technology. Keeping up with new developments is challenging and exciting. And MNOSHA investigators are one of the very few individuals with the authority to affect improvements in working conditions for all Minnesotans. If you wish to speak to someone about jobs with Minnesota OSHA, contact a MNOSHA supervisor at: • (651) 284-5050; or • toll-free at 1-877-470-6742.
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Spring 2006

Employers reducing the number of injuries to teenage workers
By Brian Zaidman, Research Analyst Research and Statistics

Summer approaches, and so does the teenage worker injury season. Since 1995, 36 percent of all injuries to workers 14 to 18 years of age have occurred during the months of June, July and August. Employers are responsible for providing a workplace that protects workers from injury, disease and fatalities. These responsibilities are even more important when there are teenage workers, who may not fully appreciate the potential dangers of work situations. Minnesota’s employers have made great progress in reducing the number of injuries to teenagers. From 1998 through 2002, there was an annual average of 664 workers’ compensation indemnity claims for teenagers. For the 2003 through 2005 period, there has been an annual average of 336 indemnity claims, a 51 percent decrease. While there has been a slight decrease in the youth employment rate since 2000, it cannot account for this large a decrease in injured workers. Workers’ compensation indemnity claims require a work disability of more than three days, and only about one-fifth of all workers’ compensation claims reach this level of severity. Thus, there are an estimated 1,700 to 2,000 claimed injuries to workers age 14 to 18 years old annually. Workers’ compensation indemnity claims from workers aged 14 to 18, for injuries that occurred between January 2003 and August 2005, were analyzed to provide the most common features of these injured workers and their injuries. • Older teenagers dominated the injury statistics; 57 percent of the injured teenagers were 18-year-olds and 27 percent were 17-yearolds.

Indemnity claims for workers 14 to 18 years old
800 700 600 500 400 300 200 100 0 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

• Workplace injuries were more likely among male workers, who accounted for 61 percent of the claims. Females accounted for 52 percent of employed Minnesotans age 16 to 19 in 2004. • As expected among this population, 58 percent of the injured teenagers had part-time or seasonal jobs.
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• Only 41 percent of the injured teenagers lived in the Twin Cities metropolitan area, compared to 48 percent among all indemnity claimants. As might be expected, injuries to teenagers were more common in the resort areas, which employ many youths during the summer months. The central lakes region, which includes the areas around Brainerd and Alexandria, accounted for 11 percent of the teenagers with claims, while only 6 percent of all workers’ compensation claimants lived in that area. • Teenager injuries were reported most frequently in the accommodations and food services industry (20 percent of claims) and in retail trade (19 percent of claims). • The two most common occupation types among injured teenagers were food preparation and serving occupations, and transportation and material moving occupations (mostly unskilled general laborers). Each occupation group accounted for 21 percent of the claims. • About 33 percent of teenager claims were for burns, cuts or fractures; 29 percent were for sprains and strains. This compares to 18 percent and 42 percent, respectively, among all workers. • Consistent with the types of injuries, the arms and hands were the most frequent body parts injured, accounting for 36 percent of the claims. • The types of events causing the injuries were most commonly bodily reaction and exertion and contact with objects and equipment. Each category accounted for 35 percent of the claims. Bodily reaction and exertion includes injuries caused by overexertion in lifting, pulling or pushing objects, and injuries due to movements such as bending, crawling or twisting. Some common events in the contact with objects and equipment category include being struck by falling or flying objects and being caught in running equipment. The OSHA Web site includes information for teenage workers and their employers at index.html. The Web site includes online tools that describe common hazards and potential safety solutions for teen workers and employers in the restaurant and agriculture industries. The Department of Labor and Industry’s Web site includes child labor standards information that summarizes state and federal laws concerning child labor and contains a list of prohibited work for minors under 18 years of age. The Web site is at www.doli.state.
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Minnesota businesses achieve MNSHARP status
MNOSHA Workplace Safety Consultation recently recognized three Minnesota businesses as Minnesota Safety and Health Achievement Recognition Program (MNSHARP) worksites: • Scott Equipment Company, New Prague; • Anchor Block Company, Shakopee; and • Reynolds Food Packaging, Rogers. For more information about MNSHARP, visit Scott Equipment Company, New Prague, Minn.

Reynolds Food Packaging, Rogers, Minn.

Anchor Block Company, Shakopee, Minn.

Workplace Safety Consultation, IBM sign alliance agreement
In March, Minnesota OSHA Workplace Safety Consultation (WSC) signed an alliance agreement with IBM, Rochester, Minn. Forming an alliance with WSC enables organizations committed to workplace safety and health to collaborate with MNOSHA to prevent injuries and illnesses in the workplace. WSC and its allies work together to reach out to, educate and lead Minnesota employers and their employees in improving and advancing workplace safety and health. Visit for more information about WSC alliances.

Clockwise from lower left: Michael Mueller, senior well-being manager, IBM; Dave Ferkul and James Collins, Workplace Safety Consultation; and DLI Assistant Commissioner of Workplace Services Roslyn Wade.
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Spring 2006

By Gary Robertson, MNOSHA Training Officer

Construction Breakfast season winding down

Winter is winding down and so are the sessions of the Minnesota OSHA Construction Breakfast program. This newsletter is too late to get you to the March 21 program, "A hands-on AWAIR program that works," but chances are the May 16 program, "Tubular welded-frame scaffold safety," can be added to your calendar. The Construction Breakfast seminars offer information that is relevant to worksite safety and are a positive addition to continued safety education. The March 21 breakfast program outlined how easy it is to understand and use the "A Workplace Accident and Injury Reduction" (AWAIR) program, a required safety program. Sixtytwo participants heard – step by step – how to customize the AWAIR program to fit an individual company's safety needs and how to be in compliance with MNOSHA. In May, the “workhorse” of scaffolds – the tubular welded-framed scaffold – is the subject of the last breakfast of the season. Micki Hentges, owner of Scaffold Services Inc., will discuss the hazards associated with the erection, use and dismantling of this scaffold. She will explain what must be done to assure the safety of employees working with each process.

MNOSHA Training Officer Gary Robertson speaks about the importance of structured worksite safety, during the March 21 Construction Breakfast in St. Paul. Sixty-two people attended the breakfast seminar, "A hands-on AWAIR program that works."

Chuck Logan, MNOSHA principal safety investigator, will briefly discuss related citation statistics associated with the use of this scaffold. To register, visit or call (651) 284-5375. Program topics presented this year were chosen by a steering committee of Minnesota’s construction stakeholders. This new approach to MNOSHA's Construction Breakfast program is the reason for the outstanding success and attendance this season. The committee continues to meet and is already selecting next year’s safety topics and presenters. Stay tuned ...
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Minnesota OSHA citations, 2005
Following a Minnesota OSHA workplace inspection, citations and penalties may be issued. Such citations indicate specific areas where an employer has been found to be in violation of regulations regarding worker safety or health. The following lists are of the top 10 most frequently cited standards for 2005; the first list is general industry and the second is construction specific. To learn how MNOSHA inspections are conducted, visit Minnesota OSHA's top 10 most frequently cited standards, 2005
Description A Workplace Accident and Injury Reduction (AWAIR) program Development and use of lockout/tagout procedures Emergency eyewash/shower facilities Employee Right-To-Know written program Employee Right-To-Know training frequency General duty clause – unsafe working conditions Overall Employee Right-To-Know training program Periodic inspections of energy control procedures (lockout/tagout) Machine guarding – general requirements Energy control program training Forklifts – employee exposure monitoring for carbon monoxide Frequency 183 161 139 134 128 124 109 104 104 103 96

– To see more of the list or for more information, visit –

Minnesota OSHA's top 10 most frequently cited standards in the construction industry (SIC codes 1521 through 1799), 2005
Description Fall protection on scaffolds above 10 feet Fall protection in residential construction General duty clause – unsafe working conditions Fall protection – general requirements A Workplace Accident and Injury Reduction (AWAIR) program Hard hats in construction Use of sloping or protective systems to prevent excavation cave-ins Railings on stairways Fall protection for roofing work on low-slope roofs Fall protection near wall openings High visibility personal protective equipment near mobile earth-moving equipment Scaffold platform not fully planked or decked Frequency 93 90 85 82 71 53 44 31 29 29 29 26

– To see more of the list or for more information, visit –

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Spring 2006

Nursing-home project update
By Dave Ferkul and Jolyn Crum, MNOSHA Workplace Safety Consultation

In 2004, Minnesota OSHA Workplace Safety Consultation (WSC) began a long term, collaborative project established to assist Minnesota nursing-home facilities to reduce the severity and occurrence of musculoskeletal injuries that occur to the members of the nursing staff, particularly the nursing assistants. (See Safety Lines, Fall 2005, at In December, WSC presented training sessions – in Duluth, St. Paul and Mankato – to further educate administrators and safety managers about reducing ergonomic risks in the workplace. Employees from 23 of the facilities that are participating in the project attended. Guest speakers provided additional information about programs and processes that are working at their facilities: • evaluating and controlling a known high-risk work task, presented by Wayne Lindberg, Louisiana-Pacific (Duluth session); • injury reporting and management, presented by Brad Honl and Christy Flaspeter, Grandview Ministries (St. Paul session); and • injury management program, presented by Sue Gluth and Laurie McPhee, New Ulm Medical Center, a WSC MNSTAR worksite (Mankato session).
Above: Dave Ferkul, MNOSHA, leads an ergonomics training session in Duluth, Minn., in December, for employers taking part in the MNOSHA Workplace Safety Consultation nursing-home project. Below: Sue Gluth and Laurie McPhee, New Ulm Medical Center, discuss their facility's successful injury management program during the Mankato, Minn., seminar in December.

Some of the attendees also offered summaries of the activities and best practices implemented in their facilities, including pilot projects involving: • the installation of ceiling lift systems; • use of repositioning aids; • involvement of rehabilitation staff members in resident assessments; • purchasing used lift equipment at discounted prices; • use of peers to assist with on-the-job training; • job-task analysis; • and injury reporting. Additional training sessions and networking opportunities are planned, including a partial tour of the New Ulm Medical Center to observe patient handling equipment, gain insight about choosing the equipment and listen to comments from staff members who use the equipment.

Recordkeeping 101: Part 6

Summarizing the injury and illness log
By Brian Zaidman, Research Analyst, Research and Statistics

Editor's note: This is the sixth installment of a series about using the OSHA Form 300 and summarizing its results. This information is directed to people who are new to OSHA recordkeeping activities, who are unfamiliar with the 2002 recordkeeping changes or who want to review their recordkeeping practices. This installment deals with the annual log summary. The previous installments are available at

This installment covers how to avoid errors when creating the annual log summary. The previous five installments of this series discussed how to fill in the log (OSHA form 300). At the end of each year, you must complete an annual log summary (OSHA form 300A). Every establishment that keeps a log must create an annual summary, even if there are no log entries. Completing the summary will help you realize the full potential of keeping the log. Information from the annual review can be used to educate employees, keep upper management apprised of safety and health issues, set goals for the coming year and prioritize safety committees activities. OSHA recordkeeping requirements list four required actions for the annual summary: • review the log entries; • create the summary; • certify the summary; and • post the summary. To best follow this installment, it would help to have an OSHA log and a summary form available. The forms are available on the federal OSHA recordkeeping Web site at recordkeeping/RKforms.html. Please note that the average employment and total hours worked worksheets are not available on the Excel version of the forms.
What to summarize

to draw a line through the nonrecordable cases or highlight the recordable ones. Sometimes, an OSHA log entry for an injury or illness that has been filed as a workers’ compensation claim is denied workers’ compensation benefits. A denial of workers’ compensation benefits has no effect on the recordability of a log entry. Each state runs its own workers’ compensation system, with its own set of laws, and liability determinations vary greatly among the states. The OSHA log is a federal recordkeeping tool and the OSHA recordkeeping requirements are the only rules in effect. A denial of workers’ compensation benefits is not a reason to remove an entry from the log.

Carefully review all the log entries. Verify that each entry is complete and accurate, and correct any deficiencies. If you need help with this task, review Recordkeeping 101: Parts 2 through 5. • Each case must have a description. Re-read each description to make sure it makes sense and fill in any missing information. • Each case must have only one box checked in columns G, H, I or J (case classification). Mark the correct classification if the status of a case has changed since it was originally entered and correct the counts of days away from work and days with job transfer or restriction. • For each case with a check mark in column H (days-away-from-work case), there must be at
16 Spring 2006

Instructions on the annual aummary form ask you to summarize only recordable cases. (See Recordkeeping 101: Part 1.) If you make log entries for all reported cases, do not include the nonrecordable cases in the summary. It may help
Safety Lines

Recordkeeping 101: Part 6 least one day entered in column K (number of days away from work). There can be no cases with entries in column K that do not also have a check mark in column H. • For each case with a check mark in column I (job transfer or restriction case), there must be at least one day entered in column L (number of days on job transfer or restriction). Each case with an entry in column L must have a check mark in either column H or I. • Each case must have one box checked in column M (injury or type of illness).
Total the columns

Minnesota OSHA Compliance (MNOSHA) (651) 284-5050 1-877-470-6742 Workplace Safety Consultation (WSC) (651) 284-5060 1-800-657-3776 Recordkeeping packet (651) 284-5042 1-800-342-5354

After all the cases have been reviewed, counting the entries and totaling the days becomes an easy task. Remember to include each page of the log if more than one page was needed to record all the cases. Enter “0” in the total if there are no cases (or days) in that column. • The sum of columns G, H, I and J must equal the sum of columns M1 to M6. • The total number of days away from work (column K) must not be less than the number of cases entered in column H. • The total number of days of job transfer or restriction (column L) must not be less than the number of cases entered in column I.
Establishment information

digit North American Industry Classification System (NAICS) code, the same NAICS code used to report employment and wages for unemployment insurance. NAICS codes are online at and can be obtained from the Minnesota Department of Employment and Economic Development at (651) 297-2242. • Computing the annual average number of employees who worked for the establishment during the year can be complicated for some businesses. A worksheet is provided on the back of the annual summary form. While the worksheet focuses on payroll employees, the OSHA recordkeeping rules also include as employees those nonpayroll workers that you supervise on a dayto-day basis. Owners of sole proprietorships and partners of partnerships are not considered employees. • The average annual number of employees is not the same as the number of full-time-equivalent workers. Do not calculate the number of fulltime-equivalent workers for this summary. • The total hours worked by all employees, both those on the payroll and those nonpayroll workers subject to day-to-day supervision by your establishment, does not include paid time away from work. If you do not have ready access to this number, use the worksheet provided on the back of the form.

The right side of the summary asks for some basic information about the work establishment, including the average annual number of workers and their total hours of work. • Fill in the establishment’s name and address, and provide a brief description of the work done at that establishment. • Provide the industry classification code for the establishment. You should already have a six-

Recordkeeping 101: Part 6
Certify the summary

Because the annual summary is an official federal form for business establishments, it is necessary for an officer of the business to sign the form to certify it is a correct and complete set of information about that establishment.
Post the summary

establishments, it may be necessary to post more than one copy. Post a copy in a conspicuous place where other notices to employees are customarily posted. You will need to periodically check that the summary is not altered, defaced or covered by other material. Completing the annual summary does not mean the injuries and illnesses from the prior year can be put to rest. Once summarized, the injury and illness data becomes a tool for monitoring and improving your establishment’s safety. There will be more on this in the next installment. The OSHA log, the summary, any privacy case list and case incidence reports must be saved for five years following the end of the year that the records cover. This means that the log and summary for 2005 injuries and illnesses must be kept through 2010.

The summary must be posted in a conspicuous place so that all employees can see their worksite’s injury and illness record and understand their worksite’s health and safety environment. • A copy of the completed summary must be posted no later than Feb.1 of the year following the year covered by the log. The summary must be kept posted until April 30. • A copy of the summary must be posted in each work establishment. In some large

Next installment: Using your log results ONLINE RESOURCES
Federal OSHA recordkeeping resources • MNOSHA recordkeeping resources • MNOSHA WSC recordkeeping training • Survey of Occupational Injuries and Illnesses • • Packet of recordkeeping forms, instructions • Booklet: Minnesota OSHA recordkeeping requirement •

Safety Lines


Spring 2006