Risk Management OSHA: Baseline Compliance for Camps The Occupational Safety and Health Administration (OSHA) has regulations that pertain to employee safety and health on the job. Occasionally, the popular press contains news of a business slapped with an OSHA fine, most typically for infraction of some rule, but rarely does someone address the application of OSHA to our camp world. This article is intended to address that need with a focus on the “common ground” OSHA elements shared by all camps. How Do Camps Fit into OSHA? Camps typically come under OSHA’s “general industry” standards. The other areas pertain to construction and manufacturing, areas typically not the backbone of camp work. So when you access OSHA information, available online at www.OSHA.gov, be sure accessed content is appropriate to general industry standards. In addition, note that OSHA regulations are national in scope, but their interpretation and many interpretive guidelines come from the state in which the business entity (camp) is located. For this reason, it’s important that you not only know what a regulation may direct, but also how your state interprets that regulation. For example, OSHA regulations direct that the OSHA Form 300 be at the location of the business entity. Some states may direct that this log, a summary of worker injury-illness reports, be physically at a specific camp while other states might allow the log to be at the camp’s primary office. This introduces a couple other aspects of OSHA. The act falls under the U.S. Department of Labor (DOL). As such, the DOL has OSHA offices in each state. One arm of that state office is consultative; one can call with questions and speak with an individual who will answer questions. The other arm is enforcement; this is the aspect that responds to employee complaints and carries out tasks such as OSHA inspections. These two branches do not inform one another; a person who calls the consulting division with a question will not trigger a directive to the enforcement division. Which OSHA Standards Impact All Camps? Keeping in mind that OSHA regulations are germane to employees (not clients/ campers), all camps should attend to OSHA standards pertaining to worker injuryillness on the job (e.g., workers’ compensation), the Hazardous Communication Standard (Haz-Com or Right-to-Know), the Bloodborne Pathogens Standard, and aspects associated with an OSHA inspection. Camp professionals tend to be well aware of the requirements of reporting employee injuries and/or illnesses that occur on the job. Often managed through one’s worker compensation carrier, these injury-illness events are reported to the state via a form called the First Report of Injury. Injuries or illnesses that are handled via first aid generally are not reported on this form. States publish interpretive guidelines that help one determine what constitutes “first aid,” an important distinction when a given camp may have an RN and/or MD at camp that sees injured/ill employees. That being said, a common problem is that camp directors neglect to inform their health center staff as to when an employee’s injury-illness event meets the criteria necessary for a First Report of Injury to be completed. Whether a health center staff member or the camp director is responsible for completing and submitting this form, it’s important that care providers know when a given event meets the reporting threshold. And, yes, the number of submitted First Report of Injury forms does affect an entity’s “modification rating.” This, in turn, influences what the entity pays to obtain workers’ compensation insurance and is well worth monitoring by the camp’s administration. From a risk-reduction perspective, having all employees understand the cycle associated with on-the-job injury and illness goes a long way to reducing these incidents. 16 CAMPING magazine • November/December 2013 One of the most often neglected components of worker injury in the camp setting is the OSHA Form 300. This one-page document is available online both as an Excel file and a PDF (go to www.OSHA.gov and enter “OSHA Form 300” or “OSHA 300 Log” into the site’s search line). The log summarizes submitted First Report of Injury claims for each year. Completed logs should be retained for five years following the end of the year to which the log pertains. In addition, a completed summary of the 300 log, a different form, should be posted from February 1st until April 30th for employees to review. The log and its summary form are available as a PDF at www.osha.gov/recordkeeping/newosha300form1 1-04.pdf. And, yes, posted summaries from February through April are an interesting challenge when camp employees are only seasonal. That’s a great question to bring to the state’s consultative OSHA division. Our camp community enjoyed robust discussions about the Bloodborne Pathogens Standard when concerns about HIV and blood exposure first surfaced. There isn’t much discussion about this topic now. Perhaps there should be? This standard directs that a business (camp): A. Determine what jobs incur risk of exposure to blood and body fluids; B. Define how management of personnel or work practices can limit that exposure; C. Establish workplace controls such as education and providing personal protective equipment (PPE); D. Define the protocol when an exposure incident occurs; E. Develop record-keeping practices specific to this standard; F. Prepare and update the entity’s written plan; G. Provide employee education as directed by the standard; and H. Consult the state’s OSHA division about compliance concerns. Linda Ebner Erceg , RN, MS, PHN continued on page 18
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