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 5.18 STUDENT AND STAFF INJURY REPORTS AND RECORDKEEPING

 
 

 Purpose

 

P1. To ensure documentation of compliance with required elements of the center’s Occupational Safety and Health program and ensure compliance with OSHA and all other applicable statutes.

P2. To notify appropriate officials that an injury, occupational illness/disease, or death has occurred.

P3. To record hazards identified and corrective actions taken, indicate trends, and provide a basis for formulating future plans.

P4. To permit an evaluation of progress being made in preventing accidents.

P5. To document incidents for assurance of proper medical treatment and potential processing of claims.

 

 Requirements

 

R1. Occupational Safety and Health Administration (OSHA) Notification Requirements

In accordance with 29 CFR 1904.39(a), centers must contact OSHA within six (6) hours of one or more of the following events:

a. Death of an active student

b. Death of a staff member on-duty

c. Hospitalization of one or more active students or on-duty staff

Centers must orally report the fatality/multiple hospitalization by telephone or in person to the Area OSHA Office nearest to the site of the incident, or use the OSHA toll-free central telephone number, 1-800-321-OSHA (800-321-6742). Should no one answer the national toll-free number you must leave a telephone message with the following information:

a. Establishment name

b. Location of the incident

c. Time of the incident

d. Number of fatalities or hospitalized employees

e. Names of any injured employees

f. A contact person’s name and his or her phone number

g. A brief description of the incident

R2. Student Injury, Occupational Ill​ness/Disease, and Fatality Recordkeeping

Occupational illness/disease in this context is defined as illness or disease acquired from/due to the Job Corps training and/or living environment (e.g., hearing loss, coronary/vascular condition, asbestos-related illness, carpal tunnel syndrome, etc.).

Student injuries and occupational illnesses/diseases must be documented in the Department of Labor’s Employees’ Compensation Operations and Management Portal (ECOMP). ECOMP is an electronic database that assists the U.S. Department in meeting the reporting requirements of both the Occupational Safety and Health Administration (OSHA) and the Office of Workers’ Compensation Programs (OWCP). The only injuries and occupational illnesses/diseases that should not be documented in ECOMP are those that occur while the student is

• at home on pass or leave
• engaged in leisure time employment, or
• in an Unauthorized Absence (UA) status.

Regardless of the severity of the injury or occupational illness/disease, an incident will minimally require the submission, in ECOMP, of the two documents below:

a. The OSHA 301, Injury and Illness Incident Report

b. One of the forms below:

1. OWCP CA-1, Notice of Traumatic Injury and Claim for Compensation

2. OWCP CA-2, Notice of Occupational Disease and Claim for Compensation (The CA-2 submission is rarely used; if you think a CA-2 is warranted, contact the National Office.)

Student fatalities are not documented in ECOMP. These incidents should be reported to the National Office of Job Corps immediately. Centers are required to complete the OWCP CA-6 manual form. The National Office will complete any other recordkeeping requirement.

A complete list of the OSHA and OWCP forms, and a description of their use, are below. Please note that all occupational safety and health records must be maintained for a five- year period, unless otherwise indicated by a specific OSHA standard, the Department of Labor Manual Series (DLMS), or the Program Requirements Handbook (PRH).

Electronic Forms Submitted in ECOMP

a. OSHA 301, Injury and Illness Incident Report, is completed in ECOMP for each student injury or occupational illness in accordance with 29 CFR 1904. The OSHA form is required to be retained for five years.

b. OSHA 300, Log of Work-Related Injuries and Illnesses: For OSHA 301 Incident Reports that are work-related (see definition in criterion 1, below), centers must maintain a single current log in ECOMP, known as the OSHA 300 Log. For an incident to be entered in the OSHA 300 Log, it must meet each of the three OSHA-recordable criteria below:

1. The injury or occupational illness is work-related. For Job Corps purposes, this means that the injury or occupational illness occurred while the student was involved in training or educational activities.

2. The injury or occupational illness represents a new case in the system.

3. The injury or occupational illness results in one or more of the following:

(a) Days away from work (training or educational activities)

(b) Restricted work or transfer to another job

(c) Medical treatment beyond first aid

(d) Loss of consciousness

(e) A significant injury or illness diagnosed by a physician or other licensed health care professional

(f) A needlestick or sharp injury exposing the student to another person’s blood or potentially infectious material

(g) A Standard Threshold Shift (STS) in hearing in one or both ears where the employee’s total hearing level is at least 25 decibels above audiometric zero in the same ear(s) as the STS

(h) Exposure to persons with a case of active tuberculosis (TB), where the student subsequently develops a TB infection.

Student injuries resulting from horseplay while engaged in training or educational activities must also be recorded. Any student injury must be recorded in the OSHA 300 Log in ECOMP.

The OSHA 300 Log is required to be retained for five years.

c. CA-1, Notice of Traumatic Injury and Claim for Compensation, is completed in ECOMP within seven calendar days of supervisor notification.

In the event that an injury requires separation from Job Corps, center staff must obtain Office of Job Corps approval prior to forwarding a CA-1 to OWCP. When the CA-1 is filed with OWCP at separation, a CA-16 manual form, Authorization for Examination and/or Medical Treatment, and an OWCP-1500 manual form, the Health Insurance Claim Form, are sent to the provider. If the injury is not severe enough to cause separation, the CA-1 should be completed, electronically filed in ECOMP within seven calendar days of supervisor notification, printed, signed by the student, and filed in the student’s health folder.

d. CA-2, Notice of Occupational Disease and Claim for Compensation, is rarely used in Job Corps because there are very few cases of occupational disease or illness related to enrollment in Job Corps. If such a situation does occur, contact the Office of Job Corps before filing a CA-2.

Manual Forms

a. CA-6, Official Supervisor's Report of Employee’s Death, is filed with the OWCP district office if a student dies as a result of an illness/injury incurred while in performance of duty. In the event of a student fatality, the Center Director must notify OWCP immediately by telephone, email, or fax, and mail the CA-6 to the OWCP district office. Do not document student fatalities in ECOMP.

The Center Director must report student fatalities to the National and Regional Offices within six hours of the event via Significant Incident Report (SIR).

b. CA-7, Claim for Compensation Due to Traumatic Injury or Occupational Disease: Unlike other federal employees, Job Corps students are not eligible for continuation of pay for 45 days. However, they may submit a CA-7 after medical separation to receive compensation for injury or illness. The center must complete the CA-7 and have the student sign and date Section 7 of the form. In the event that the student is unable to sign the CA-7, the Center Director may sign as his or her authorized representative.

Upon Office of Job Corps approval to forward a CA-1 or CA-2 to OWCP in ECOMP, the center must fax or e-mail a copy of the completed CA-7 to the Office of Job Corps for submission to OWCP. The Office of Job Corps must file the copy sent to them by the center with OWCP within five days of the student’s signature.

The original CA-7, signed by the student, should be filed in the student’s health folder.

c. CA-16, Authorization for Examination and/or Treatment: Whenever a student separates from Job Corps and needs examination and/or treatment as a result of traumatic injury, the Center Director should issue a CA-16 to the physician or medical facility. This form authorizes the injured student's examination and/or treatment from a physician or medical facility. When a CA-2 is electronically submitted to OWCP in cases of separation because of work-related illness or disease, a CA-16 is issued only if prior approval is obtained from OWCP. If a CA-16 is submitted, do not submit a CA-20.

This form provides OWCP with an initial medical report and the physician or medical facility with a billing form for emergency treatment. Issuance of the CA-16 authorizes OWCP to pay medical expenses incurred.

Part A is completed by the student’s supervisor and submitted to the physician or medical facility within 48 hours of examination and/or treatment. Part B is completed by the attending physician as promptly as possible after initial examination and sent to the appropriate OWCP district office.

When there is a need for medical follow-up for the work-related injury by a second health-care provider, the center must email/mail the name and address of that provider to OWCP or instruct the student (in writing) to do so.

d. OWCP-1500 (also known as HCFA-1500)—Health Insurance Claim Form:

This form accompanies the CA-16 to all medical care providers, except hospitals.

It is issued by health-care providers to bill the OWCP district office for services rendered.

e. CA-20, Attending Physician’s Report: This report provides medical support of claims for compensation. It is submitted to OWCP upon completion of the medical examination and treatment. It is also used to provide additional medical information regarding the claim. If a CA-20 is submitted, do not submit a CA-16.

R3. Definitions and Procedures for Handling Job Corps Student Injuries

a. Job Corps Injuries Designated as First Aid

1. First aid is defined as any one-time treatment, and any follow-up visit for the purpose of observation, of minor scratches, cuts, burns, or splinters, which does not ordinarily require medical care. Such one-time treatment and follow-up visits are considered first aid even if they are provided by a physician or other registered professional personnel.

2. First aid injuries must be documented in ECOMP.

3. The following procedures are generally considered first aid treatment (e.g., one-time treatment and subsequent observation of minor injuries):

(a) Application of antiseptics during initial visit to medical personnel

(b) Treatment of first degree burn(s)

(c) Application of bandage(s) during any visit to medical personnel

(d) Use of elastic bandage(s) during initial visit to medical personnel

(e) Removal of foreign bodies from wound if procedure is uncomplicated (e.g., by tweezers or other simple technique)

(f) Use of nonprescription medications and administration of single dose of prescription medication on initial visit for minor injury or discomfort

(g) Soaking therapy on initial visit to medical personnel or removal of bandages by soaking

(h) Application of hot or cold compress(es) during first visit to medical personnel

(i) Application of ointments to abrasions to prevent drying or cracking

(j) Application of heat therapy during first visit to medical personnel

(k) Negative x-ray diagnosis

(l) Observation of injury during visit to medical personnel

4. The administration of a tetanus shot or booster by itself is not considered medical treatment. However, these shots are often given in conjunction with more serious injuries; consequently, injuries requiring these shots may be filed in ECOMP for other reasons.

b. More Serious Injuries Not Resulting in Student Separation

1. This category includes injuries that result in medical treatment beyond first aid, and are serious enough to need a specialized referral but do not require a medical separation.

2. An example of this type of injury would be a student sustained a strain or sprain, but is able to continue training with restrictions.

3. These injuries must be documented in ECOMP. Some examples of this category of injury are:

(a) Fractures

(b) Head injuries with loss of consciousness

(c) Positive x-ray diagnosis

(d) Lacerations with nerve or tendon damage

(e) Injuries needing sutures/SteriStrips/adhesive butterfly

(f) Foreign body embedded in the eye

(g) Jaw fractures/dental damage

(h) Treatment of infection

(i) Treatment of 2nd- or 3rd- degree burns

(j) Food poisoning

(k) Dislocated shoulder

c. Injuries Resulting in Separation from Job Corps

1. This category includes injuries resulting in the student’s death or serious injuries that result in the student’s separation from Job Corps.

2. An example of this type of injury would be: a student sustained a traumatic injury in the performance of duty that requires surgery, additional medical treatment that cannot be provided on center, or the student can no longer perform in the program.

3. These injuries must be documented in ECOMP.

4. Section 8143 of the Federal Employees’ Compensation Act (FECA) states that while students are enrolled in Job Corps, students are considered employees of the federal government for purposes of medical coverage under FECA. The performance of duty does not include an act of an enrollee while absent from his or her assigned post of duty, except while participating in an activity (including an activity while on pass or during travel to or from the post of duty) authorized by or under the direction and supervision of Job Corps.

R4. Staff Injury, Occupational Illness/Disease, and Fatality Recordkeeping

Staff is defined as all contractors, federal employees, and temporary employees who work at a Job Corps center.

All work-related staff injuries and occupational illnesses must be documented in the Department of Labor’s Employees’ Compensation Operations and Management Portal (ECOMP) in accordance with 29 CFR 1960 Subpart I​ and 29 CFR 1904. These regulations require that a single OSHA 300 Log be maintained for each federal agency establishment; each Job Corps center is classified as an establishment. As such, all work-related injuries and occupational illnesses suffered by federal employees and contractors at the establishment must be captured on the same OSHA 300 Log. This requirement has no bearing on the requirements of the corporate office or other federal agency.

Centers are only required to report the death of a staff member if the fatality occurs while in duty status on- or off-center. The Center Director must report staff deaths to the National and Regional Offices within six hours of the event via Significant Incident Report (SIR).

A CA-1 or CA-2 is never completed for staff in the Department of Labor’s ECOMP.

a. OSHA 301, Injury and Illness Incident Report, is completed in ECOMP for each staff injury or occupational illness in accordance with 29 CFR 1904. The OSHA form is required to be retained for five years.

b. OSHA 300, Log of Work-Related Injuries and Illnesses: All centers must maintain a single current log in ECOMP of all work-related accidents, injuries, and occupational illnesses incurred by students and staff in accordance with 29 CFR 1904. The OSHA 300 Log is required to be retained for five years.

Staff injuries resulting from horseplay while engaged in work-related tasks or activities must also be recorded. Any staff injury must be recorded in ECOMP.

R5. OSHA Form 300A, Summary of Work-Related Injuries and Illnesses

Each year, Job Corps centers are required to post OSHA Form 300A, also called the OSHA 300A Summary, from February 1 through April 30 in accordance with 29 CFR 1904.32​. OSHA Form 300A summarizes data contained in the OSHA 300 Log, which is maintained electronically in ECOMP, for the calendar year just prior to posting for the purpose of notifying students and staff of the injuries that have occurred on center. This report may be generated through ECOMP reports.

Following the required three-month posting period, the OSHA 300A must be retained for five years.

 

 Legal/CFR Requirements

 
  
29 CFR 1904
29 CFR 1904.32
29 CFR 1904.39(a)
29 CFR 1960 Subpart I