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Safety Policies & Programs


OSHA Recordkeeping

Policy Key Points

  1. Compliance with OSHA Standards
    • Yaskawa is committed to meeting or exceeding all Occupational Safety and Health Administration (OSHA) standards, including applicable state plans that may have stricter requirements.
  2. OSHA Reporting Requirements
    • Reporting Timeline: The Vice President of Human Resources or a designated representative must report certain incidents to OSHA within specific time frames:
      • Within 8 hours: All work-related fatalities and, in California, any serious injuries.
      • Within 24 hours: All work-related inpatient hospitalizations, amputations, or losses of an eye.
    • Reportable Incidents: Incidents are reportable even if the condition becomes apparent after some time, such as a delayed hospitalization for surgery related to the initial incident.
  3. Record Keeping
    • Documentation: Maintain records such as the Safety Manual, training records, inspection reports, incident reports, investigation reports, and OSHA logs.
    • Incident Reports: Complete an OSHA 301 form (or equivalent) for each work-related injury, illness, or near miss. These records must be retained for at least five years.
    • OSHA 300 Log: Maintain a log of work-related injuries and illnesses for each Yaskawa location in the U.S., recording incidents within seven working days of notification.
  4. OSHA 300A Summary Posting
    • Posting Period: Display the OSHA 300A Summary at each U.S. location from February 1 to April 30 of the following year.
    • Electronic Submission: Beginning in 2017, Yaskawa electronically submits workplace injury and illness data as required.
    • Responsibility: Human Resources manages the OSHA logs and the posting of the OSHA 300A Summary.

Policy

Introduction

OSHA, the Occupational Safety and Health Administration, is a federal agency created within the Department of Labor to develop and enforce mandatory job safety and health standards. Some US States have their own OSH plans that meet or exceed federal OSHA requirements. The states shaded in blue in the following diagram currently have state plans (the gray shaded states have plans that only affect state and local government workers):

Yaskawa Safety and Health Policies shall meet or exceed the standards established by OSHA and applicable state plans.

OSHA Reporting

The Vice President of Human Resources, or their designee, will report to OSHA within 24-hours (8-hours for fatalities and for California associates) any of the following:

  • All work-related fatalities (within 8-hours of finding out about it)
  • All work-related inpatient hospitalizations of one or more employees,
  • All work-related amputations (loss of limb or part of a limb),
  • All work-related losses of an eye
This reporting must also occur if the reporting condition appears after some time following the incident. For example, an injury is reportable if a person is not initially hospitalized for an injury but several months later is hospitalized to have surgery related to the initial incident.

Work-related fatalities involving heart attacks must also be reported, though OSHA may investigate to determine if the event was truly work-related.

Reporting Mechanisms


Federal OSHA:
Report to OSHA by:
  • Calling the nearest OSHA office, or
  • Calling the OSHA 24-hour hotline 800-321-6742,, or
  • Submitting an online report through OSHA's website.
California OSHA: Report to California OSHA by:
  • Calling the nearest California OSHA office, or
  • Calling the California 24-hour hotline.
Reports to California OSHA must occur within 8-hours of notification of the incident becoming an OSHA reportable incident.

OSHA Records

Records are maintained to document Yaskawa’s efforts to comply with OSHA standards and to provide a safe and healthful workplace. These records consist of the Yaskawa Safety Manual, safety training records, safety inspection records, incident reports, safety investigation reports, and OSHA logs. These records are subject to OSHA review and shall be made available upon request by an authorized OSHA representative.

Injuries and illnesses Incident Reports (OSHA 301 or equivalent) must be completed to record details of each work related injury, illness, or near miss. Records of these reports are retained by Yaskawa for a minimum of five (5) years.

OSHA 300 Log
An OSHA 300 log of work related injuries is maintained for each Yaskawa America, Inc. location within the United States.

OSHA requires that each “recordable” occupational injury and all occupational illnesses be recorded within seven (7) working days after being reported to Yaskawa.

Work related injuries and illnesses must be recorded on the OSHA 300 log for any of the following conditions:
  • Death,
  • Days away from work,
  • Restricted work,
  • Job transfer,
  • Medical treatment beyond first aid
    NOTE: OSHA has specific definitions of what is defined as first aid. Any medical treatment that is not on this list is "beyond first aid."
  • Loss of consciousness,
  • A significant injury or illness diagnosed by a healthcare professional, even if it does not result in days away from work, job transfer, or restricted work (e.g. cancer, chronic irreversible diseases, fractured bones)

OSHA 300A Summary
The OSHA 300A summary is posted at each Yaskawa America, Inc. United States location from February 1 until April 30 of the year following the year covered by the form. Beginning in 2017, Yaskawa America, Inc. electronically posts workplace injury and occupational illness data per OSHA requirements. Human Resources is responsible for maintaining OSHA logs and posting the OSHA 300A Summary.

Job Safety and Health Protection Poster

The OSHA Job Safety and Health Protection poster (or related in facilities with State plans) shall be posted in a conspicuous place where notices to employees are customarily posted at each office, shop, and job-site.

OSHA Inspections

OSHA inspections may be conducted by OSHA inspectors at any workplace, and are conducted without advance notice. This procedure is an outline of the steps to be taken in the event of an OSHA inspection. We shall be courteous and cooperative, and we shall also protect our legal rights under the Occupational Safety and Health Act. Inspections must be conducted during regular work hours, and without unreasonable disruption of the work.

If an OSHA inspector comes to any Yaskawa location, he/she is to remain in the lobby until one of the OSHA Coordinator’s is contacted (try contacting in the order they are listed):

  • David Thurwanger
  • Craig Espevik
  • Cory McHugh
  • Nancy Flowers
  • Mike Salentine
  • Mike Moran
  • Paul Janda
  • Greg Lockwood
Site manager is the senior member of management present at the time of the audit.

The site manager shall follow the direction of the OSHA coordinator.

The site manager shall:
  • Verify the OSHA Compliance Officer's (inspector) credentials. If there are any questions, phone the OSHA Regional Office for confirmation.
  • Make detailed notes of the conferences and inspection. Include the OSHA inspector's name and ID number.
  • Document the time of the inspector's arrival, start and finish of the walk-through, and departure.
  • Document the purpose of the inspection.
  • Document conference topics and names of all persons present.
  • Document the names of the people the inspector interviews.
  • Documents the names, titles, and affiliations of any third-party who may be accompanying the OSHA Compliance Officer.
  • Document the areas inspected.
  • Document the operations observed.
  • Document the records requested:
    • All requests for documentation shall be in writing. Do not provide any documents at the time of the inspection (except OSHA logs, Hazard Communication Policy, and Safety Data Sheets).
    • The OSHA Coordinator will coordinate record requests.
  • Document photos taken. Take similar pictures then take a second picture with a wider field of vision to properly identify the scale and surrounding area.
  • Document videos taken. Take similar videos.
  • Document measurements taken. If possible, take a similar measurement with Yaskawa equipment.
  • Document the inspector's comments and potential citations.
  • DO NOT agree with any citations.
  • Provide the inspector access to any work area they request within the inspection guidelines (see below) and ensure the inspector adheres to all safety rules in effect.

Inspection Guidelines

If the inspection is to confirm abatement of previous citations, those citations are the only valid topic for the conference and inspection.

If the inspection is due to a compliant, obtain a copy of the complaint. Only the specific subject of that complaint is to be discussed and inspected. If an inspector observes another hazard en route to inspect the subject of a complaining or re-inspection, however, that hazard becomes subject to inspection.

Pre-Inspection Conference

In facilities with a bargaining unit, the inspector may request that an employee representative (Union Steward) be present. This request must be granted.

In all facilities, the OSHA inspector may ask an employee representative if they want a third party to assist the OSHA compliance officer. In these cases, contact the OSHA coordinator for guidance.

The inspector will request to interview employees in private. This request is to be granted.

Compliance Officer Walk-Around Inspection

If this is a re-inspection, escort the compliance officer to only the specific areas involved with the re-inspection.

If this is an inspection due to a complaint, escort the inspector only to the specific areas related to the complaint or referral.

If the inspector points out any obvious infractions during the walk-around, correct these at once (if feasible) but do not agree that it was a violation.

Post-Inspection Conference

At the post inspection conference, the OSHA Compliance Officer will discuss their observations and conclusions about potential citations.
  • The inspector does not have the authority to issue a citation.
  • DO NOT admit to any violations or agree to any specific abatement dates.
  • Following the conference, the inspector is to be escorted off the premises.

Records Related to this Policy

  • OSHA 301 or equivalent (First Report of Incident Form)
  • OSHA 300 Log maintained by Human Resources
  • OSHA 300A Summary maintained by Human Resources and posted in conspicuous area from February 1 through April 1 of the year following the reporting year


Training

OSHA coordinators and associates likely to serve as a site inspection manager shall be provided with training related to this policy.

Revision History

Rev # Description Release Date Approved by
0 Conversion of old safety documents, rewrite, and issue 5/19/2016 Thurwanger
1 Added requirement for OSHA electronic submissions 10/12/2016 Thurwanger
       

Program Review

Review Date Reviewed by Changes Required (Yes/No) Revision # if updated
2/21/2017 Thurwanger No
1/16/2018 Thurwanger No
1/22/2019 Thurwanger No  
1/14/2020 Thurwanger No
1/21/2021 Thurwanger No
1/18/2022 Thurwanger No
1/31/2023 Thurwanger No
1/16/2024 Thurwanger No
1/21/2025 Thurwanger No

Policy Video