NA EHS OSHA RECORDKEEPING PROGRAM

OVERVIEW

WHO DOES THIS PROGRAM APPLY TO?

This program applies to all Amazon NA Operations Leaders and
Personnel.

WHO NEEDS TO BE TRAINED FOR THIS PROGRAM?

See the EHS Training Matrix & Calendar and Section 5 of this
document.

1.0 PROGRAM.................... 1
WHAT PROGRAM DOCUMENTS ARE REQUIRED TO BE 2.0 SITE PLAN ..................... 8
COMPLIANT?
3.0 WORK INSTRUCTIONS... 9
Monthly Reconciliation Confirmation
Monthly Reconciliation Meeting Minutes Recordkeeping Protocol .. 9
Procedure for Amazon Recordkeeping (PARk) Request Site Reconciliation ......... 12
Workers’ Compensation Document Review
4.0 FORMS ....................... 15
Monthly Reconciliation
Confirmation ................. 15
WHO HAS THE RESPONSIBILITY TO IMPLEMENT AND MAINTAIN
THE PROGRAM? Job Transfer or
All NA Operations Leaders Restriction ..................... 17
Site Safety Team
Site Human Resources Team Monthly Reconciliation
Meeting Minutes ........... 19
PARk Process ................. 20
Workers’ Compensation
WHAT ARE THE LEGAL REQUIRMENTS THAT MUST BE FOLLOWED?
Document Review ......... 21
OSHA 29 CFR 1904: Recording and Reporting Occupational
Injuries and Illnesses 5.0 IMPLEMENTATION ..... 24
6.0 REVISION HISTORY ..... 25
State Regulations:
KY- 803 KAR 2:180
WA- WAC 296-800-32005
CA- CCR Title 8 Section 342
NA EHS OSHA RECORDKEEPING 1.0 PROGRAM

1. Purpose
1.1. The purpose of this program is to ensure sites are compliant with OSHA’s Recordkeeping
Standard 29 CFR 1904.
1.2. Under this program, Site Leadership and Operations Management are required to record and
report work-related injuries, illnesses and fatalities upon initial notification.

2. Scope
2.1. This program applies to the leadership teams within NA Operations. This includes FC, Sort,
AMZL, Fresh and Pantry, and MOD. This does not include Prime Now.

3. Definitions
3.1. Assigned working hours: those hours the employee is actually expected to work, including
overtime.
3.2. Non-routine functions: work activities the employee performs less than once per week
3.3. Procedure for Amazon Recordkeeping (PARk): The appeals process by which an ambiguous
recordable injury or illness is confirmed to be non-recordable. These types of incidents are
assumed recordable until proven otherwise through well-founded, conclusive evidence.
3.4. Recordable incident: A work-related injury or illness that results in death, days away from
work, restricted work, job transfer, or medical treatment beyond first-aid, or that meets the
specific case criteria
3.5. Restricted work: Restricted work occurs when, as the result of a work-related injury or illness,
(a) an employer keeps the employee from performing one or more of the routine functions of
his or her job, or from working the full workday that he or she would otherwise have been
scheduled to work; or (b) a physician or other licensed health care professional recommends
that the employee not perform one or more of the routine functions of his or her job, or not
work the full workday that he or she would otherwise have been scheduled to work
3.6. Routine functions: work activities the employee regularly performs at least once per week.
3.7. Work environment: the establishment and other locations where one or more employees are
working or are present as a condition of their employment. The work environment includes not
only physical locations, but also the equipment or materials used by the employee during the
course of his or her work
3.8. For Additional Definitions - See Recordkeeping Protocol.

4. Roles and Responsibilities

4.1. Site Leader/ GM
4.1.1.Assign responsible personnel to oversee implementation and monitor for effectiveness
4.2. Site Leadership
4.2.1. Confirm that incidents are reported, investigated and documented in accordance with the
Incident Reporting and Investigation Program.
4.2.2. Create incident reports for all work-related injuries of temporary, leased, or contractor
employees Amazon supervises on a daily basis; if Amazon does not supervise them on a
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daily basis, the site Safety Manager should coordinate with the employer to make sure the
employer records the injuries.
4.3. Site Safety Team
4.3.1. Recordkeeping determinations are made by the Site Safety Team.
4.3.2. Accurately enter recordables on the OSHA Log within seven days of being aware that
recordable/lost-time criteria have been met.
4.3.3. On a weekly basis, validate injury and illness data in Gensuite via the weekly verification
process in Incidents & Measurements.
4.3.4. On a minimum monthly basis, reconcile the information in Gensuite, OSHA Accuracy Form
and OSHA Log, Workers’ compensation records, and on-site medical logs. Any
discrepancies between Workers’ compensation records and Gensuite records must be
noted in Gensuite.
4.3.5. Ensure that all restricted and lost time work days are accurately entered into Gensuite.
4.3.6.Where required under the Occupational Noise and Hearing Conservation Program, all
associates that have been identified by a medical professional as having a Standard
Threshold Shift (STS) of greater than or equal to 10 dBA at the 2,000, 3,000, and 4,000 Hz
range and 25 dB above audiometric zero must be entered into Gensuite and logged as an
incident (not recordable) if a retest is scheduled within 30 days. If a retest (to be
conducted within 30 days of original test) is conducted and it is determined that a
recordable STS shift has not occurred the case is not recorded on OSHA log.
4.4. WC/AMCARE/HR
4.4.1. AMCARE OMRs are responsible for uploading case documentation. At no point should
Amcare OMRs make recordkeeping decisions or be involved in the decision making
process.
4.4.2. When contact must be made with a physician regarding a work-related injury or illness,
only the WC Specialist, AMCARE or HR contacts the physician. At no time, shall the site
Safety Manager contact an outside physician with regard to a work-related injury or
illness. All calls from AMCARE to Physicians must be within the protocols of the AMCARE
program.
5. Training Requirements
5.1.1. Refer to the Safety Training Matrix for training requirements. This includes the Course Name,
Module ID, required frequency and category of Affected Personnel that require training.
5.1.2. Refer to the Safety Trainer Qualifications Matrix for trainer qualifications.

6. Procedure
6.1. Post Injury or Illness
6.1.1. Log recordable/lost-time incidents within seven days of being made aware that recordable
criteria has been met;
6.1.2. Keep an updated OSHA log (within Gensuite) of all injuries in accordance with the OSHA
regulations.

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6.1.3. For cases involving job transfer or restricted work, utilize Restricted Work guidance and
complete Restricted Work Form.
6.1.4. Update Gensuite when appropriate so that the OSHA Log reflects newly discovered injuries
or illnesses and changes to injury classifications.
6.1.5. At the end of the calendar year, fill out and certify an OSHA 300A Summary of Injuries and
Illnesses; obtain approval and signature from the site leader and post it at the work site
from February 1 through April 30 of the following year.
6.1.6. Upon report of an incident that is fatal to one or more associates or that causes
admittance to a hospital of any associate, immediately notify the Regional Safety Manager,
EHS Director, Legal Department, Risk Management (using contact information found in the
Amazon Phone Tool) and log incident in the Outside Agency Inspection Recap SharePoint
site. Refer to the Outside Regulatory Agency Inspection and Communication Program for
additional guidance.
6.1.7. Government Agency Incident Reporting Requirements:
6.1.7.1.Within 8 hours after the death of an associate OR within 24 hours of all work-
related inpatient hospitalizations, all amputations and all losses of an eye, report the
incident by calling the OSHA Area Office or OSHA’s toll-free number 1-800-321-6742
(OSHA).
6.1.7.1.1. Only fatalities occurring within 30 days of the work-related incident must be
reported to OSHA. Further, for an inpatient hospitalization, amputation or loss
of an eye, these incidents must be reported to OSHA only if they occur within
24 hours of the work-related incident. See additional OSHA Reporting FAQ’s in
section 4.
6.1.7.2.Note: Some states may have different reporting requirements. For sites in CA, KY
and WA, use the variations in State Reporting Requirements listed below:
6.1.7.2.1. California: Within 8 hours of incident that causes fatality, or any serious injury
or illness, by calling the nearest District Office of the Division of Occupational
Safety and Health. [CCR Title 8 Section 342]
6.1.7.2.1.1. A “Serious injury or illness"" means one which requires inpatient
hospitalization for a period in excess of 24 hours for other than medical
observation or in which an employee suffers a loss of any member of the
body or suffers any serious degree of permanent disfigurement.
6.1.7.2.2. Kentucky: Report the work-related death of an employee or in-patient
hospitalization of 3 or more employees within 8 hours, or the hospitalization of
1 or 2 employees or amputation suffered by any employee within 72 hours, by
calling Kentucky DOSH Compliance at (502) 564-3070 or OSHA toll-free # 1-800-
321-OSHA. [803 KAR 2:180].
6.1.7.2.3. Washington: Within 8 hours of a work related incident that results in a
fatality or the inpatient hospitalization of any employee, or within 24 hours of a
work-related incident that results in either an amputation or the loss of an eye
that does not require inpatient hospitalization, report the incident by calling
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the nearest Labor & Industries office at 1-800-423-7233 or OSHA toll-free # 1-

800-321-OSHA. [WAC 296-27-031]

6.2. Hearing Conservation (if applicable)

6.2.1. Obtain list of associates required to be in the site Occupational Noise and Hearing
Conservation Program.
6.2.2. Confirm all associates and Mangers required to be in this program have had their annual
hearing test.
6.2.3. Review hearing test and retest results to determine any Standard Threshold Shifts (STS) of
10 dBA or greater.
6.2.4. Review all STS cases with overall hearing level 25dB or more above audiometric zero in the
same or both ears.
6.2.5. Review all medical reports to determine if the STS of 10 dBA or greater and overall
hearing level is 25 dB or more above audiometric zero in the same or both ears is work-
related and recordable.
6.2.6. Log all work-related hearing loss cases in Gensuite as recordable.
6.2.7. If a hearing loss case is believed to not be work related, contact IH Program Manager to
aid in the PARk process.
6.3. Reconciliation & Auditing
6.3.1. On a weekly basis, complete validation of I&I Log in Gensuite. Verification review includes
hours worked and I&I log case accuracy.
6.3.2. By the 5th of each month verify the previous month’s monthly validation of I&I Log in
Gensuite. Hours worked and cases are auto-populated.
6.3.3. On a monthly basis, by the end of the second full week of the month, a reconciliation of
records from Safety, AMCARE, Human Resources, Workers’ Compensation (WC) Records
and Agency Records must be performed following the Site Safety Record Reconciliation
Process. Document the Reconciliation Meeting using the Reconciliation Meeting Minutes
document and upload the minutes to the Safety Compliance Calendar. If all stakeholders
are not present at the Reconciliation Meeting, the meeting must stop and the absence
escalated to the regional safety manager. Note: Attendees may call in if not available in
person. In the event all attendees are not able to attend at the same time, the
representative (HR, OMR, WC, GM) may sign off prior to the meeting to ensure
reconciliation occurs within 48 hours of the scheduled meeting.
6.3.4. Obtain Workers’ compensation records from previous month from the Risk
Management/WC Representative for Amazon and Staffing Agency associates, obtain
records from AMCARE Representatives, and obtain incident records and work-related
medical information pertinent to the case from Human Resources or WC Specialist.
6.3.5. Follow the Site Safety Record Reconciliation Process to reconcile incidents listed in the
Workers’ Compensation logs, AMCARE records, and HR records with records in Gensuite
and ensure that all cases are entered in Gensuite, and that any instances where associates
were given medical treatment beyond first aid, as outlined in the Recordkeeping Protocol

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and OHSA Regulation 29 CFR 1904, are appropriately marked as recordable or marked with
the reasons the case was not recordable.
6.3.6. Discrepancies shall be researched and described. When associates are seen by a medical
provider and the case is not recorded, indicate as such in the “Recordability Rationale” box
in the safety incident report in the Gensuite and listing the reason for the discrepancy.
Note: The Recordablity Rationale must be completed for all cases and should be used to
explain why or why not the case is recordable.
6.3.7. Confirm that restricted and lost time work days are accurately entered into Gensuite.
6.3.8.Create a master file, to be housed in AMCARE, for all cases. This file shall contain: A copy
of the incident report, the Workers’ Comp Medical Review Document, any WC documents,
any emails or overrides and documents pertinent to the work related case (examples:
emails about Transitional Work Assignments (TWA), restrictions, recordability
determinations). [If AMCARE is not on-site, the files shall be located under the control of
the Site Safety Manager in a secure location]
6.3.9. After completion of the reconciliation process the Site Safety Manager, GM/Site Leader
and Regional Safety Manager must sign the Monthly Site Injury and Illness Records
Reconciliation Confirmation document. Note: At the request of the Regional Safety
Manager, a Sub-Regional Safety Manager may perform this task, in their place, provided
that the Sub-Regional Safety Manager is not also currently serving as the Safety Manager
for the site.
6.3.10. On a quarterly basis, the Regional Safety Manager shall audit the site’s reconciliation
documents for accuracy.
6.3.11. On an annual basis, the Site Safety Manager shall audit the OSHA log for accuracy. This
review shall be completed in December and finalized in January for the previous calendar
year.
6.4. PARk Consideration
6.4.1. PARk Eligibility
6.4.1.1. The following situations shall be eligible for PARk consideration:
6.4.1.1.1. Work-related injuries or illnesses resulting in restricted work or job transfer
where no other recordability criteria (section 5.1.3 of the Recordkeeping
Protocol) is met
6.4.1.1.2. Injuries or illnesses where work-relatedness is undetermined
6.4.1.2. The following situations shall not be eligible for PARk consideration:
6.4.1.2.1. Because they are recordable
6.4.1.2.1.1. Work-related injury or illness resulting in days away from work
Work-related injury or illness treated with medical treatment beyond
first-aid
6.4.1.2.1.2. Work-related cases involving death, cancer, tuberculosis, chronic
irreversible disease, a fractured or cracked bone, punctured eardrum,
standard threshold shift, loss of consciousness, or needle stick injury,

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regardless of whether there was lost time, work restriction, or medical

treatment received
6.4.1.2.2. Because they are non-recordable
6.4.1.2.2.1. Non-work-related injuries or illnesses
6.4.1.2.2.2. Work-related injuries or illnesses that do not result in days away from
work, restricted work or job transfer, medical treatment beyond first-aid,
nor satisfy any other recordability criteria in section 5.1.3 of the
Recordkeeping Protocol
6.4.2. PARk Procedure
6.4.2.1.PARk procedure is not compulsory for all eligible injuries and illnesses. Site safety
teams shall have the authority to record a PARk eligible case if it meets the
recordability criteria in Section 5 of the Recordkeeping Protocol, or if there is
insufficient evidence to prove the case non-recordable.
6.4.2.2.The following procedure shall be followed for cases that the site safety team
determine are non-recordable.
6.4.2.2.1. The site safety team shall complete a PARk form in Gensuite, and upload
supporting documents for review and approval.
6.4.2.2.2. The site safety lead (e.g. safety manager (or the safety manager's designee),
lead safety specialist, or site operations point of contact designated and trained
for this role, in sites without onsite safety support) shall review, approve, and
submit the PARk form and supporting documents into the PARk approval
process. In their absence, the safety manager will assign a single site safety
specialist to act as the proxy for this role.
6.4.2.2.3. The PARk case request shall be reviewed and approved by both
6.4.2.2.3.1. the manager of the site safety manager (at a minimum regional safety
manager level); and
6.4.2.2.3.2. one regional senior EHS leader, randomly chosen
6.4.2.2.4. If the PARk is approved then the workflow will note approval from the two (2)
different approvers.
6.4.2.2.5. If the PARk process is rejected by the approvers or not approved within seven
(7) days of the case meeting OSHA recordkeeping criteria, then the case must
be logged, recorded in Gensuite as a recordable and then follow the normal
process of notifying the network.
6.4.2.2.6. If an eligible case was recorded and after further review the site determines
the case does not meet recordkeeping criteria, the case will still need to gain
PARk approval and then be redlined in Gensuite (to support the decision to
remove the case from the OSHA log).
6.4.2.2.7. All non-recordable justifications must be documented utilizing the Gensuite
PARk form within the Incidents and Measurements application.
6.4.2.2.8. Cases that have a workers compensation claim but do not meet recordable
criteria, for example, cases that visited an occupational health provider but
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received only first-aid treatment, will be expedited to a single second approver,

chosen at random.
6.4.2.3. Supporting documents
6.4.2.3.1. At a minimum, the PARk request shall be accompanied with the following
documents:
6.4.2.3.1.1. A justification description concisely summarized in one or two
paragraphs
6.4.2.3.1.2. The completed PARk form
6.4.2.3.1.3. All of the Requests for Medical Information (RFIs) or records of medical
condition from a Physician or License Health Care Provider (PLHCP) for
the case
6.4.2.3.1.4. The First Report of Incident (FROI)
6.4.2.3.1.5. A description of the incident or incident report (if an incident report
exists); provided that if an incident report has been conducted under
attorney-client privilege, only a non-privileged description of the Incident
shall be provided
6.4.2.3.1.6. All of the AmCare and first-aid care notes directly related to that event
6.4.2.3.2. In addition to the items listed above, additional supporting documentation
may be required to support the PARk application. The following information
should be evaluated for inclusion with the PARk request:
6.4.2.3.2.1. Timeline of events
6.4.2.3.2.2. Employee statements
6.4.2.3.2.3. Witness statements
6.4.2.3.2.4. Relevant or applicable workers compensation information
6.4.2.3.2.5. Associate pick/pack/stow history
6.4.2.3.2.6. Associate injury and treatment history
6.4.2.3.2.7. The Job Safety Analysis (JSA)
6.4.2.3.2.8. The following documents shall not be considered as evidence and
should not be included with supporting documentation.
6.4.2.3.2.8.1. Associate AMP information
6.4.2.3.2.8.2. Video footage of the identifiable event, area, or incident
6.4.2.4. PARk approval requirements
6.4.2.4.1. For each PARk case request, the approvers must evaluate in the context of the
OSHA recordability criteria: the event, associate work duties, associate non-
work activities, the work environment, and the medical information to confirm
non-work-relatedness.
6.4.2.4.1.1. Restricted work or job transfer
6.4.2.4.1.1.1. Restricted work occurs when, as the result of a work-related
injury or illness, (a) an employer keeps the employee from
performing one or more of the routine functions of his or her job, or
from working the full workday that he or she would otherwise have
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been scheduled to work; or (b) a physician or other licensed health

care professional recommends that the employee not perform one
or more of the routine functions of his or her job, or not work the
full workday that he or she would otherwise have been scheduled
to work
6.4.2.4.1.1.2. For work-related injuries or illnesses resulting in restricted work
or job transfer where no other recordability criteria (section 5.1.3 of
the Recordkeeping Protocol) is met, the following shall be provided
in the supporting documentation, the absence of which shall result
in a denial of the PARk.
6.4.2.4.2. Indisputable evidence that the effected or recommended work restriction or
job transfer did not involve routine functions. Routine functions are work
activities that the employee regularly performs at least once per week. See
Table 1 for examples.

Table 1: Examples of work-restriction recordability

Recordable Non-recordable
An employee has a work-related injury and is An employee has a work-related injury and is
given a 20 lb. lifting restriction. The restriction is given a 20 lb. lifting restriction. The restriction is
given because the employees works in shipping, given because the employees may get rotated for
which may involve lifting up to 50 lb. on a daily equipment breakdown, where lifting is required,
basis. Since the restriction involves one of the once or twice a month. Since the employee is
employee’s routine tasks, this would be a restricted only from this non-routine task, and no
recordable case. other routine functions are affected, this would
be a non-recordable case.
An employee has a work-related injury and is An employee has a work-related injury and is
given a restriction that they should not work in given a restriction that they should not work in
stow. The employee regularly rotates between stow. The employee works in pick, but once every
stow, pick, water spider (depending on what the few weeks may work a shift in stow. Because
site needs that day). The employee can continue stow is a non-routine function for this employee,
to pick and perform the water spider functions, this would be a non-recordable case.
but because stow was part of the employee’s
routine functions this would be a recordable
case.

6.4.2.4.2.1. Undetermined work-relatedness

6.4.2.4.2.1.1. For injuries or illnesses where work-relatedness is
undetermined, the following shall be provided, the absence of
which shall result in a denial of the PARk.
6.4.2.4.2.1.1.1. Evidence beyond a reasonable doubt that the events or
exposures that occurred in the work environment did not

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cause or contribute to the resulting condition, or significantly

aggravate a pre-existing injury or illness; or
6.4.2.4.2.1.1.2. Evidence that a work-relatedness exception from
section 5.2.3 of the Recordkeeping Protocol applies

6.5. Privacy Cases

6.5.1. For cases that involve need for privacy, the associate’s name may be omitted from the
OSHA log to protect and “Privacy Case” will be entered.
6.5.2. A separate confidential log of associate’s name must be maintained.
6.5.3.Privacy cases may include any of the following:
6.5.3.1. Cases involving injury or illness to intimate body part or reproductive system
6.5.3.2. Injury or illness resulting from sexual assault
6.5.3.3. Mental illnesses
6.5.3.4.Needlestick or exposure to bloodborne pathogens (Note: These cases must also be
maintained on Sharps Log as specified by Bloodborne Pathogens program)
6.5.3.5. Other illnesses, where associate requests name not be listed.
6.5.4.To further protect privacy, for example in a sexual assault cases, the details may also be
limited to prevent identifying the associate.

7. Reporting, Recordkeeping, and Record Retention

7.1. Required Documentation:
7.1.1. Electronic training records of Affected Personnel (FC Training Console, KNet or equivalent)
7.1.1.1. Training Records must include: Date training was completed, Course name, Module
ID (if appropriate), Location training was completed, and Instructor and Trainee names.
7.1.1. One completed Annual Self-Review
7.1.1.1. See Annual Self-Review
7.1.1.2.Program Specific Documentation: Monthly Site Injury and Illness Records
Reconciliation Confirmation that documents the monthly reconciliation of
discrepancies between HR, Safety, and/or AMCARE.
7.1.1.3. PARk Request Forms
7.1.1.4. Monthly Reconciliation Meeting
7.1.1.5. OSHA 300 injury logs, 301 incident reports, and 300A summaries or equivalents.
7.2. Retention:
7.2.1. Training records shall be retained for the Associate’s length of employment or a minimum
of one (1) year. Documentation of EHS training shall be maintained for at least one (1)
year.
7.2.2. Annual Self-Review retained for one year.
7.2.3. Monthly Site Injury and Illness Records Reconciliation Confirmation and Monthly
Reconciliation Meeting Minutes shall be uploaded to the Safety Compliance Calendar by
the end of the second full week of the month and maintained for five years.
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7.2.4. OSHA 300 Injury logs, 301 incident reports, and 300A summaries for five years.

8. Evaluation
8.1. Safety Managers and Site Leaders / GMs review all work-related injuries with treatment beyond
first aid that are not logged as recordable.
8.2. Master files exist that contain all required documentation.
8.3. One completed Annual Self-Review (first quarter execution recommended).
8.4. Completion of External Peer Review as scheduled.
8.5. The Annual Self-Review should include an independent completion of the Monthly Site Injury
and Illness Records Reconciliation Confirmation document and shall include all open cases.
8.6. Recordkeeping requirements are fulfilled (documented and retained) according to Section 5.

9. Legal Requirements
9.1 OSHA 29 CFR 1904: Recording and Reporting Occupational Injuries and Illnesses
9.2 State Regulations:
9.2.1 CA- CCR Title 8 Section 342
9.2.2 KY- 803 KAR 2:180
9.2.3 WA- WAC 296-800-32005

10. References
10.1 Incident Reporting and Investigation
10.2 Occupational Noise and Hearing Conservation
10.3 Outside Regulatory Agency Inspection and Communication Program

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Amazon Confidential Page 11 Revision Date: 25 November 2016

NA EHS RECORDKEEPING PROTOCOL 3.0 WORK
INSTRUCTIONS

1. Purpose
1.1. The purpose of this work instruction is to provide assistance in the interpretation of regulatory
information supplied by OSHA regarding its Recording and Reporting Occupational Injuries and
Illnesses standard.
1.2. The Amazon internal safety metrics are based on OSHA regulatory requirements for work-
related injury and illness recordkeeping that are described in OSHA 29 CFR 1904. For more
information on applying and interpreting OSHA 29 CFR 1904, refer to the OSHA Recordkeeping
Handbook, or to the OSHA Website.

2. Scope
2.1. This instruction is intended for all leadership and support function personnel within all Amazon
Fulfilment Centers.

3. Defining Injuries and Illnesses

3.1. An injury or illness is considered work-related if an event or exposure in the work environment
causes or contributes to the condition or significantly aggravates a preexisting condition.
3.2. Work-relatedness is presumed for injuries and illnesses that result from events or exposures
that occur in the workplace, unless a specific exception applies.
3.3. The “work environment” includes the establishment and other locations, including employer-
owned parking lots, where one or more employees are working or are present as a condition of
their employment.
3.4. Injuries can include cuts, fractures, sprains, and amputations.
3.5. Illnesses can be either acute or chronic, such as skin diseases, respiratory disorders, or
poisoning.

4. First Aid vs. Medical Treatment

4.1. First Aid
4.1.1.When an incident requires only the following types of treatment, consider it first aid and
not a recordable. This list is to be considered all-inclusive. If it is not included on the first
aid list, it has to be recorded as medical treatment. Do NOT record the case if it involves
only:
• Using non-prescription medications at non-prescription strength;
• Administering tetanus immunizations;
• Cleaning, flushing, or soaking wounds on the skin surface;
• Using wound coverings, such as bandages, BandAids™, gauze pads, etc., or using
SteriStrips™ or butterfly bandages.
• Using hot or cold therapy;
• Using any totally non-rigid means of support, such as elastic bandages, wraps,
non-rigid back belts, etc.;
• Using temporary immobilization devices while transporting an accident victim
(splints, slings, neck collars, or back boards).
• Drilling a fingernail or toenail to relieve pressure, or draining fluids from blisters;
• Using eye patches;
• Using simple irrigation or a cotton swab to remove foreign bodies not embedded
in or adhered to the eye;
• Using irrigation, tweezers, cotton swab or other simple means to remove
splinters or foreign material from areas other than the eye;
NA EHS RECORDKEEPING PROTOCOL 3.0 WORK
INSTRUCTIONS

• Using finger guards (non-rigid);

• Using massages;
• Drinking fluids to relieve heat stress.

4.2. Medical Treatment

4.2.1.Medical treatment includes managing and caring for a patient for the purpose of
combating a disease or disorder.
4.2.1.1. Medical Treatment beyond first aid shall not be administered by Amazon
Associates or Managers at any time. Medical Treatment beyond first aid
provided by Amazon Associates or Managers will be considered recordable and
should be logged in Gensuite.
4.2.2.Work-related injuries or illnesses requiring medical treatment are generally recordable,
but the following situations are not considered medical treatments and therefore are
NOT recordable:
• Visits to a doctor or health care professional solely for observation or counseling;
• Diagnostic procedures, including X-rays and administering prescription medications
that are used solely for diagnostic purposes; and
• Any procedure that can be labeled first aid. (See above for more information about
first aid.)

5. Recordable Cases
5.1. This Program requires that an injury or illness case be considered recordable if it:
5.1.1. Is work-related: An event or exposure in the work environment either caused or
contributed to the resulting condition, or significantly aggravated a pre-existing injury or
illness; unless one of the exceptions from section 5.2.3 of this standard applies; and
5.1.2. Is a new case: The employee has not experienced a recorded injury or illness of the same
type that affects the same body part, or the employee has recovered completely (all signs
and symptoms had disappeared) from the previously recorded injury or illness and an
event or exposure in the work environment caused the signs or symptoms to reappear;
and
5.1.3. Meets one of the following general recording criteria:
5.1.3.1. Results in death, days away from work, restricted work or job transfer, medical
treatment beyond first-aid, or loss of consciousness; or
5.1.3.2. Is the result of a needle stick injury or cut from any sharp object contaminated
with another person’s blood or potentially infectious material; or
5.1.3.3.Is one of the following, diagnosed by a licensed medical professional: cancer,
tuberculosis, chronic irreversible disease (e.g. byssinosis, silicosis, etc.), fractured
or cracked bone (including fingers, toes, and teeth), punctured eardrum, or
standard threshold shift
5.2. Determining work-relatedness
5.2.1.When an employee is seen by a Physician or Licensed Health Care Provider (PLHCP),
work-relatedness shall be determined by the Request for Medical Information (RFI)
completed by that PLHCP. Otherwise, work-relatedness shall be determined by the site
safety team in accordance with the requirements that follow.
5.2.2.An injury or illness shall be considered work-related if an event or exposure in the work
environment either caused or contributed to the resulting condition or significantly
aggravated a pre-existing injury or illness. It is important to note that the event or
NA EHS RECORDKEEPING PROTOCOL 3.0 WORK
INSTRUCTIONS

exposure need only be one of the discernible causes for a case to be considered work-
related; it does not need to be the sole or predominant cause of the injury or illness.

5.2.3. Work Relatedness Exceptions

5.2.3.1.Work-relatedness is presumed for injuries and illnesses resulting from events or
exposures occurring in the work environment, except where:
5.2.3.1.1. At the time of the injury or illness, the employee was present in the
work environment as a member of the general public rather than as an
employee.
5.2.3.1.2. The injury or illness involves signs or symptoms that surface at work but
result solely from a non-work-related event or exposure that occurs
outside the work environment.
5.2.3.1.3. For this exclusion to apply, there must be absolutely no event or
exposure in the work environment that caused or contributed to the
signs or symptoms. For example, this exception might apply if an
associate with reflex epilepsy had a seizure at work, assuming there
were no triggers for the seizure in the workplace (e.g. flashing lights).
However, if triggers existed in the workplace then the exclusion might
not apply. For instance, if the seizure was triggered by sleep deprivation
resulting from the employee working a shift configuration that did not
afford them ample time to sleep (e.g. 8pm to 6am, immediately
followed by 8am to 6pm), this exclusion would not apply.
5.2.3.1.4. The injury or illness results solely from voluntary participation in a
wellness program or in a medical, fitness, or recreational activity such as
blood donation, physical examination, flu shot, exercise class,
racquetball, or baseball.
5.2.3.1.5. The injury or illness is solely the result of an employee eating, drinking,
or preparing food or drink for personal consumption (whether bought
on the employer's premises or brought in). For example, if the
employee is injured by choking on a sandwich while in the employer's
establishment, the case would not be considered work-related.
Note: If the employee is made ill by ingesting food contaminated by
workplace contaminants (such as lead), or gets food poisoning from
food supplied by the employer, the case would be considered work-
related.
5.2.3.1.6. The injury or illness is solely the result of an employee doing personal
tasks (unrelated to their employment) at the establishment outside of
the employee's assigned working hours.
5.2.3.1.7. The injury or illness is solely the result of personal grooming, self-
medication for a non-work-related condition, or is intentionally self-
inflicted.
5.2.3.1.8. Personal grooming activities are activities directly related to personal
hygiene, such as combing or drying hair, brushing teeth, or clipping
fingernails. It does not include adjusting the fit of safety equipment,
tying shoelaces, or bathing or showering at the workplace when
necessary because of an exposure to a substance at work. For example,
a burn injury from a hair dryer used at work to dry the employee's hair
NA EHS RECORDKEEPING PROTOCOL 3.0 WORK
INSTRUCTIONS

would not be work-related. A fall injury sustained while using the

shower or eyewash station to remove a contaminant to which the
employee had been exposed at work would be work-related.
5.2.3.1.9. The injury or illness is caused by a motor vehicle accident and occurs on
a company parking lot or company access road while the employee is
commuting to or from work.
5.2.3.1.10. The illness is the common cold or flu (Note: contagious diseases such as
tuberculosis, brucellosis, hepatitis A, or plague are considered work-
related if the employee is infected at work).
5.2.3.1.11. The illness is a mental illness. Mental illness will not be considered
work-related unless the employee voluntarily provides the employer
with an opinion from a physician or other licensed health care
professional with appropriate training and experience (psychiatrist,
psychologist, psychiatric nurse practitioner, etc.) stating that the
employee has a mental illness that is work-related

6. General Recording Criteria: Below is a list of treatment and/or conditions which would meet the
general recording criteria defined in OSHA 29 CFR 1904.7(a). Provided are the definitions which are
commonly associated with work-related injuries and illnesses:
6.1. Death: Any work-related incident that results in the death of the associate must be recorded.
6.2. Job Transfer- OSHA defines Job Transfer as a situation where:
• An injured or ill employee is assigned to a job other than his or her regular job for part of the
day.
• A case is recordable if the injured or ill employee performs his or her routine job duties for
part of a day and is assigned to another job for the rest of the day. OSHA also states that:
• Most job transfers involve some type of restriction. Even if they don’t, job transfers due to
an injury or illness are recordable events. If an injured or ill employee is transferred to
another job for half days, this is also a job transfer.
• If a permanent job transfer is made immediately, that is, on the day of injury or illness, at
least one day of restricted work activity must be recorded.
Number
6.3 Loss of Consciousness: Any work-related injury or illness that results in a loss of consciousness
must be recorded.
6.4 Lost Time: Any work-related injury or illness where the associate is determined by a licensed
health care professional to be unable to work one or more full work shifts not to include the
date of injury.
6.5 Medical Treatment Beyond First Aid: Any treatment not listed as first aid in 29 CFR 1904
6.5.1 Examples include, but are not limited to:
• Prescription medication: Over the counter medication at or above prescription
dosing
• Hepatitis (following exposure)
• Rabies (following injury)
• Suture
• Staple
• Surgical Glue
NA EHS RECORDKEEPING PROTOCOL 3.0 WORK
INSTRUCTIONS

• Cast
• Splint
• Rigid brace
• Eye injuries which embedded or adhered objects which require more complicated
procedures
• Physical therapy

6.6 Restricted Work: Restricted work activity occurs when, as the result of a work-related injury or
illness, an employer or healthcare professional keeps, or recommends keeping, an employee
from doing the routine functions of his or her job, or from working the full workday that the
employee would have been scheduled to work before the injury or illness occurred, not to
include the date of injury.

6.7 Significant Aggravation of Injury or Illness- According to OSHA 29 CFR 1904.5:

6.7.1 “There must be significant aggravation of a pre-existing injury or illness to establish
work-relatedness. The workplace event or exposure must aggravate a pre-existing
injury or illness enough that it results in greater consequences than what would have
occurred but for that event or exposure. This means that the pre-existing condition
requires more medical treatment than otherwise needed.” OSHA further states, “A
pre-existing injury or illness is significantly aggravated when an event or exposure in
the work environment results in any of the following (which otherwise would not have
occurred):
• Death
• Loss of consciousness
• Days away, days restricted or job transfer
• Medical treatment
NA EHS SITE INJURY AND ILLNESS RECORDS RECONCILIATION 3.0 WORK
PROCESS INSTRUCTIONS

1. Purpose
1.1 The purpose of this work instruction is to provide a process that ensures the accuracy of the NA
Amazon OSHA 300A and 300 log by reviewing all sources of work-related injury data.
2. Scope
1.1 Work-related injury documentation from Human Resources (HR), Safety, AMCARE, Amazon
Workers’ Compensation (WC) and Agency Representative shall be reviewed and reconciled
on a minimum monthly basis. All appropriate supporting documentation to support the
reasons for the discrepancies shall be filed onsite.
1.2 A Regional Safety Manager review will be conducted Quarterly.
1.3 An OSHA Log review will be completed Annually.

3. Procedure

Weekly Process: Weekly verification of OSHA log accuracy and hours worked shall be completed by
Safety Team using the weekly verification feature in Gensuite Incidents & Measurements.

Monthly Process (Note: This monthly process may occur more frequently for larger FCs)

CHECK #1: OSHA 300 log accuracy check

Print out OSHA Form 300 from Gensuite and confirm for the current year:

 Total numbers on the bottom of each page are accurate based on check marks and days
listed.
 “Body Part” and “Describe injury or illness” is accurate.
 Employees’ name and job title are accurate.

Print out OSHA Form 300A from Gensuite and confirm for the current year:
 Total number of cases, days, and “injury and illness types” match information in the OSHA
300 log.
 For each case verify restricted days and/or lost work days are correct.
 Information on the right side of the form is complete and accurate (establishment
information, employment information, etc.).
 Correct year in the upper right hand corner.

CHECK #2: Work-related injury and illness records reconciliation check

1. Schedule a minimum monthly meeting with HR, AMCARE, Amazon WC Representative and
Agency WC Representative.
2. Obtain Workers’ compensation claim run reports from the Amazon WC team and the Agency
WC team to review during the meeting.
3. Compare the Associate names against the OSHA 300log and identify the cases that are not listed
in the OSHA 300 log.

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NA EHS SITE INJURY AND ILLNESS RECORDS RECONCILIATION 3.0 WORK
PROCESS INSTRUCTIONS

4. Discuss cases that are not logged as recordable to determine if the case should be recordable.
NOTE: For assistance in determining work-relatedness refer to the OSHA Regulation and to the
Recordkeeping Handbook. The reasons for NOT accepting the case as recordable must be
supported by the regulations outlined in OSHA 29.CFR.1904, and/or OSHA’s Recordkeeping
Handbook and must be documented using citations from the Handbook or Standard.
5. Document meeting minutes using the Reconciliation Meeting Minutes Template. Distribute
meeting minutes to General Manager/Site Leader, Safety Manager, WC Manager, and HR
Manager. File for a minimum of 5 years. Decisions based on personal medical information will
be redacted from any notes and not distributed.

Hearing Conservation Program Reconciliation Check (if required):

1. Obtain list of Associates required to be in the site Hearing Conservation Program and confirm all
Associates and Mangers required to be in this program have had their hearing test.

2. Review hearing test results to determine any Standard Threshold Shifts (STS) of 10 dBA or greater.
Review all medical reports to determine if the STS of 10 dBA or greater and average of 25dB above
audiometric zero is work-related and recordable. NOTE: From OSHA 1910.95 – “a standard
threshold shift is a change in hearing threshold relative to the baseline audiogram of an average of
10 dB or more at 2000, 3000, & 4000 Hz in either ear.”
• Log all work-related hearing loss cases in Gensuite as recordable.
• Work with Workers’ Compensation to ensure all cases are appropriate managed.

CHECK #3: GENSUITE Reconciliation physical checks

1. For each case identified in Check #2 above, confirm:

2. Each case is listed in the GENSUITE – even if the case is listed as “non-work related.”

3. If the case is not recordable, ensure that all reasons for not accepting the cases are documented
in the GENSUITE in the “recordability rationale” section. In addition, the PARk Request form,
signed by two regional safety managers, and all supporting documentation to support the
reasons for the discrepancies shall be filed in the Gensuite I&M or equivalent System. NOTE:
The reasons for NOT accepting the case as recordable must be supported by the regulations
outlined in OSHA 29.CFR.1904 OSHA Recordkeeping Standards and/or OSHA’s Recordkeeping
Handbook.

4. Complete the monthly verification in Gensuite by the 5th of each month for the previous month.

CHECK #4: Monthly Site Injury and Illness Records Reconciliation Confirmation

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NA EHS SITE INJURY AND ILLNESS RECORDS RECONCILIATION 3.0 WORK
PROCESS INSTRUCTIONS

1. The site Safety Manager completes the “Site Injury and Illness Records Reconciliation”
document on a monthly basis.
2. This document shall be completed and uploaded to the Safety Compliance Calendar by the 21st
of each month.
3. The site safety manager, the General Manager/Site Leader, the HR Representative, the
AMCARE OMR, the Amazon and Agency WC Representatives, and the Regional Safety Manager
shall each sign (or provide email approval – attached to the document) each Monthly Site
Safety Records Reconciliation Confirmation document and retain onsite for a minimum of 5
years. Note: At the request of the Regional Safety Manager, a Sub-Regional Safety Manager
may perform this task, in their place, provided that the Sub-Regional Safety Manager is not also
currently serving as the Safety Manager for the site.

Annual Process (Note: Annual Process must occur every December and January)

CHECK #1: OSHA 300 log accuracy check

1. Print out OSHA Form 300 and 300A from Gensuite and confirm for the previous year:
2. Total numbers on the bottom of each page are accurate based on check marks and days
listed above are accurate.
3. “Body Part” and “Describe injury or illness” is accurate.
4. Employees’ name and job title are accurate.
5. Print out OSHA Form 300A and 300 from Gensuite and confirm for the previous year:
o Total number of cases, days, and “injury and illness types” match the information in
the OSHA 300 log.
o Information on the right side of the form is complete and accurate (establishment
information, employment information, etc.).
o Correct year in the upper right hand corner.
6. Print OSHA 300A and OSHA 300 Log and require the General Manager / Site Leader to sign
the Log.
7. By February 1st, post the OSHA 300A l in a conspicuous place where all Associates will have
notice and shall remain posted until April 30th.
8. Verify the site has a copy of the OSHA logs for the 5 prior years always available and an
OSHA log accuracy check is complete for the signed logs.

Amazon Confidential Revision Date: 25 November 2016

NA EHS MONTHLY RECONCILIATION 4.0 FORMS

Instructions for use: The site Safety Manager or their competent designee shall complete the Site Safety Records
Reconciliation Document on a monthly basis. All OPEN cases shall be reviewed each month so that cases with a
change in medical status and/or treatment are not missed. This document shall be completed and uploaded to the
Safety Compliance Calendar by the 21st of each month. The Site Safety Manager, the General Manager/Site
Leader, the Regional Safety Manager, and the attendees of the reconciliation meeting shall sign each Monthly Site
Safety Records Reconciliation Confirmation document and retain for a minimum of 5 years.
FC: Click here to enter text. Month/Year: Click here to enter text. Person Completing Document: Click
here to enter text.

Check 1- OSHA 300 Accuracy Check - Monthly Summary of Injury Records

Step 2 Step 3 Step 4

Step 1
Obtain Obtain number of non-
Obtain number of non-
Total Open Cases from number of recordable cases with
recordable cases with
Amazon Claim Run recordable GENSUITE Discrepancy where
GENSUITE Discrepancy where
cases from medical treatment was
medical treatment beyond first
the provided (Ensure each has a
aid was not provided.
Total Open Cases from GENSUITE: PARk Request Form)
(PARkForm required).
Agency Claim Run
+

Total of ALL open

Total
cases
**** IF Step 1 does not equal Steps 2-4, you must provide an explanation of the

Provide explanation here of any discrepancy in the numbers

above

☐ The site has performed a full accuracy check of the OSHA 300 Log to confirm OSHA 300 Log and OSHA 300 A
match the data listed above.
☐ Verify site has completed weekly validation of I&I Logs in Gensuite.
☐ Verify number of restricted and lost workdays are correct for the year. Review Restricted Work forms for each
case.
☐ Review any new cases, case status changes, or redline cases from previous month(s).

Check 2- Reconciliation of Work Related Injury and Illnesses

☐ A minimum monthly meeting occurred with Safety, HR, AMCARE, Amazon WC Representative and Agency WC
Representative to review and reconcile injury and illness records.
Attendee Signatures (attach email approval if signature not provided):
Safety Manager: Amazon WC
Representative:
HR Representative: Agency WC
Representative:
AMCARE OMR:
☐ Meeting minutes were documented outlining each case discussed and reasons for taking / not taking the case
as recordable. Meeting minutes were distributed to General Manager/Site Leader, Safety Manager, WC
Manager, HR Representative, and Agency Representative.
☐ For each case where a medical treatment beyond first aid is provided, but the Site Safety Manager deems the
case to be not recordable, the PARk Request Form is complete with all supporting documents included in the
master file and discrepancy noted in Gensuite “Recordabilty Rationale” field.

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NA EHS MONTHLY RECONCILIATION 4.0 FORMS

☐ For each case where a case meets general recording criteria per OSHA 1904.7(a), but the Site Safety Manager
deems the case to be not recordable, the site has confirmed the reasons for not accepting the injury as
recordable are in compliance with the OSHA 29 CFR 1904 Recordkeeping Standards and Recordkeeping
Handbook.
☐ (If applicable) For all Standard Threshold Shifts (STS), the site confirmed has logged the STS as work-related per
OSHA 29 CFR 1910.95.

Check 3- GENSUITE Reconciliation Physical Checks

☐ All injury and illness cases identified through incident reports, workers’ compensation claims, AMCARE medical
records are all documented accurately in Gensuite with appropriate incident type marked and necessary
incident details, including but not limited to: days of restriction, days away from work, medical treatment
(excluding any personal/pre-existing medical diagnosis, conditions or otherwise HIPPA protected
documentation), any applicable notes, etc...

To be completed by Safety Manager - By signing this document, to the best of my knowledge, all appropriate
checks have been completed to ensure the accuracy of the OSHA 300 log and OSHA 300 A.

Site Safety Manager Date

To be completed by General Manager/Site Manager – By signing this document I have confirmed the Site’s Injury
and Illness Records Reconciliation Process occurred this month.

General Manager / Site Leader Date

To be completed by the Regional Safety Manager (or Sub-Regional Safety Manager, as described above) – By
signing this document I have confirmed that I have reviewed and agree with the information listed above.

Regional Safety Manager Date

Amazon Confidential Revision Date: 25 November 2016

NA EHS JOB TRANSFER 4.0 FORMS

CHECKLIST FOR RESTRICTED WORK AND JOB TRANSFER CASES

When an Associate is placed on work restrictions due to an injury or illness, use this checklist to determine
whether the injury/illness must be recorded on the OSHA 300 log as a “Job transfer or restriction” case:

1. Review the work restrictions recommended by the health care provider and compare them to the
Associate’s job duties.

2. An injury or illness must be recorded as a “Restricted Work” case if:

1. It keeps the Associate from performing one or more of the “routine” functions of his/her job; or
2. It keeps the Associate from working the full work day that he/she would ordinarily be scheduled to
work; or
3. The health care provide recommends that the Associate not perform one or more routine functions
or not work his/her full work day.
An Associate’s “routine” job functions are those that he/she regularly performs at least once a week. Use
Exhibit A to document in detail the specific accommodations (including any job transfer) that are made for
the Associate in light of the work restrictions recommended by the health care provider.

3. Exception: A case is not recordable if:

1. The Associate experiences minor musculoskeletal discomfort; and
2. A health care provider determines that the Associate is fully able to perform all of his/her routine
job duties; and
3. Amazon assigns a work restriction to the Associate for the purpose of preventing a more serious
condition from developing.

4. If it is unclear whether the health care provider’s recommended work restrictions qualify as a “Restricted
Work” case (for example, vague recommendations such as “light duty”), contact the health care provider to
get clarification.

5. Record “Restricted Work” cases on the OSHA 300 log by:

1. Checking the box for “Job transfer or restriction”; and
2. Entering the total number of calendar days missed (including weekends, holidays, and other days
the associate is not otherwise expected to work); and
3. Not counting the day on which the injury or illness occurred.

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NA EHS JOB TRANSFER 4.0 FORMS

JOB RESTRICTIONS/ JOB TRANSFER

Please use this form to document in detail the specific accommodations (including any job transfer) that are
made for an Associate in light of the work restrictions recommended by the health care provider. Once
completed, this form should be placed with and maintained as part of the Associate’s file. If you have any
questions about how to complete this form, please contact [ ].

Associate’s Name:

Associate’s Job Description:

Date Injury Occurred:

Detailed Description of Accommodations and/or Job Transfer:

Amazon Confidential Revision Date: 25 November 2016

 NA EHS MONTHLY SITE INJURY AND ILLNESS RECORDS RECONCILIATION MEETING MINUTES 4.0 FORMS

Purpose: The purpose of this document is to provide the site safety manager with a template to use during the Monthly Site Injury and Illness
Reconciliation Meeting to ensure all cases have been reviewed and followed through until the case is closed by Worker’s Compensation.

FC: Click here to enter text. Month / Year: Click here to enter text. Person Completing Document: Click here to enter text.

Attendees: (If all are not present, the meeting must stop and the absence escalated to the Regional Safety Manager).

Safety Manager: Amazon WC

Representative:
HR Agency WC
Representative: Representative:
AMCARE OMR:

Instructions for Use: For each case listed in the Worker’s Compensation Claim Run, complete the following information (insert as many lines as
necessary to capture all cases):

Worker’s Gensuite Case Associate Is there an Case Loss Description (from Body Part (from WC What Is the case If not recordable, If the case meets general
Comp Claim ID Login encounter Status WC Claim Run) Claim Run) Treatment was recordable? was Gensuite recording criteria per
Run File (optional) – in Gensuite (Open / Description Does Body Part Does Provided? (Y or N) Recordability 1904.7(a), but the site deems
Number remove for this Closed this this (Restrictions, Rationale box a the case to be not recordable,
before case? and Match Match Prescription, reason listed? has a PARk Request Form been
posting to (Y or N) Discharge the the PT, or other (Y or N) completed?
Safety d/ Gensui Gensuit treatment (Y or N)
Compliance Treating / te e? beyond first
Calendar Declined ) Injury (Y or N) aid?)
Detail
Field?

Amazon Confidential Revision Date: 25 November 2016

NA EHS PARk REQUEST FORM 4.0 FORMS

Purpose: This document is to be completed by the site Safety Manager or their designee when an associate’s injury or illness
meets general recording criteria as defined in OSHA 1904.7(a), but the site deems the case to be not recordable. This form will
also be used if the case was originally recorded on OSHA logs and later determined to be not recordable.

Site Location: Person completing form: Today’s Date:

Case ID (from Gensuite Database): Associate’s Name:

Date of incident: Redline Case: ☐ Yes ☐ No
Reason Case was not recorded (select 1 or more that apply):
☐ Doctor deemed case non-work related
☐ Doctor confirmed that incident did not cause a significant aggravation of pre-existing condition
☐ Doctor claims injury does not match mechanism of injury

Summary of Justification Description (Always Required)

NOTE: For assistance in determining work-relatedness refer to the OSHA Regulation and to the Recordkeeping
Handbook. The reasons for NOT accepting the case as recordable must be supported by the regulations outlined in
OSHA 29.CFR.1904, and/or OSHA’s Recordkeeping Handbook and must be documented using citations from the
Handbook or Standard.

In addition you are required to include the following documents (where applicable) that support the site’s determination of not
recording:

☐ Workers’ Compensation Medical Review Document ☐ Timeline of Events

Relevant and applicable workers compensation
information
☐ Witness Statements ☐ Employee Statement
☐ (Always required) AMCARE Notes ☐ (Always required) First Report of Injury (FROI)
☐ (Always required) All RFI’s related to the case ☐ (Always required) Incident Report
☐ Labor Tracking documentation ☐ JSA
☐ Other:

This summary form, the above listed documents, and the Safety Incident Report shall be placed in the Incident Master File and
stored in the Gensuite I&M system per the implementation steps for five years.

Amazon Confidential Revision Date: 25 November 2016

NA EHS OSHA INCIDENT REPORTING FAQ 4.0 FORMS
(Reference Section 6.1.7)

This section provides Frequently Asked Questions regarding OSHA reporting requirements for Fatalities,
Hospitalizations, Amputations, and loss of an eye. Additional incident reporting FAQ can be found on
the OSHA web page.

1. What if the fatality, in-patient hospitalization, amputation, or loss of an eye does not occur
during or right after the work-related incident?
If a fatality occurs within 30 days of the work-related incident, or if an in-patient hospitalization,
amputation, or loss of an eye occurs within 24 hours of the work-related incident, then you
must report the event to OSHA. If the fatality occurs after more than 30 days of the work-
related incident, or if the in-patient hospitalization, amputation, or loss of an eye occurs after
more than 24 hours after the work-related incident, then you do not have to report the event to
OSHA. However, you must record the event on your OSHA injury and illness records, if you are
required to keep OSHA injury and illness records.

2. What if I don't learn about a reportable fatality, in-patient hospitalization, amputation, or loss of
an eye right away? Or what if I cannot determine that it was work-related right away?
You must report to OSHA within the following time period after the fatality, in-patient
hospitalization, amputation, or loss of an eye is reported to you or to any of your agent(s) and
you determine that it is work-related: 8 hours for a fatality, and 24 hours for an in-patient
hospitalization, an amputation, or a loss of an eye.

3. What information do I have to give to OSHA when I report the fatality, in-patient hospitalization,
amputation, or loss of an eye?
You must give OSHA the following information for each fatality, in-patient hospitalization,
amputation, or loss of an eye:
• The establishment name;
• The location of the work-related incident;
• The time of the work-related incident;
• The type of reportable event (i.e., fatality, in-patient hospitalization, amputation, or loss of
an eye);
• The number of employees who suffered a fatality, in-patient hospitalization, amputation, or
loss of an eye;
• The names of the employees who suffered a fatality, in-patient hospitalization, amputation,
or loss of an eye;
• Your contact person and his or her phone number; and
• A brief description of the work-related incident.

4. Do I have to report the fatality, in-patient hospitalization, amputation, or loss of an eye if it

resulted from a motor vehicle accident on a public street or highway?
If the motor vehicle accident occurred in a construction work zone, then you must report the
fatality, in-patient hospitalization, amputation, or loss of an eye to OSHA. If the motor vehicle
accident occurred on a public street or highway, but not in a construction work zone, then you
do not have to report the fatality, in-patient hospitalization, amputation, or loss of an eye to

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NA EHS OSHA INCIDENT REPORTING FAQ 4.0 FORMS
(Reference Section 6.1.7)

OSHA. However, you must record the event on your OSHA injury and illness records, if you are
required to keep OSHA injury and illness records.

5. Do I have to report the fatality, in-patient hospitalization, amputation, or loss of an eye if it

occurred on a commercial or public transportation system?
No, you do not have to report the fatality, in-patient hospitalization, amputation, or loss of an
eye to OSHA if it occurred on a commercial or public transportation system (e.g., airplane, train,
subway, or bus). However, you must record the event on your OSHA injury and illness records, if
you are required to keep OSHA injury and illness records.

6. Do I have to report a fatality or in-patient hospitalization caused by a heart attack?

If the heart attack is related to a work-related incident, you must report the fatality or in-patient
hospitalization. Your local OSHA Area Office director will decide whether or not to investigate
the incident.

7. Do I have to report a fatality caused by a heart attack at work? 1904.39(b)(5)

Yes, your local OSHA Area Office director will decide whether to investigate the incident,
depending on the circumstances of the heart attack.

8. How does OSHA define "in-patient hospitalization"?

OSHA defines in-patient hospitalization as a formal admission to the in-patient service of a
hospital or clinic for care or treatment.

9. Do I have to report an in-patient hospitalization that involves only observation or diagnostic

testing?
No, you do not have to report an in-patient hospitalization that involves only observation or
diagnostic testing. You must only report each in-patient hospitalization that involves care or
treatment.

10. How does OSHA define "amputation"?

An amputation is the traumatic loss of a limb or other external body part. Amputations include a
part, such as a limb or appendage, that has been severed, cut off, amputated (either completely
or partially); fingertip amputations with or without bone loss; medical amputations resulting
from irreparable damage; amputations of body parts that have since been reattached.
Amputations do not include avulsions (tissue torn away from the body), enucleations (removal
of the eyeball), deglovings (skin torn away from the underlying tissue), scalpings (removal of the
scalp), severed ears, or broken or chipped teeth.

Amazon Confidential Revision Date: 25 November 2016

 NA EHS WORKERS COMPENSATION MEDICAL DOCUMENTATION

PURPOSE: The purpose of the Workers’ Compensation Medical Document Review Statement is to provide
the site safety manager with the information necessary to provide a comprehensive review of all safety
incidents where medical treatment beyond first aid was provided to the injured associate/manager and the
decision was made to not log the case as recordable.

INSTRUCTIONS FOR USE: As a part of the monthly recordkeeping reconciliation process, the site safety
manager shall request the workers’ compensation specialist (or Agency Claims Representative) to complete
the statement provided below for each case where medical treatment beyond first aid was provided and
the determination was made to not log the case as recordable. The completed statement will then be
attached to the PARk Request Form and placed in the master file for the safety incident.

Name of Injured Person:

Employer of Injured Person:  Amazon
 Staffing Agency
Name of Staffing Agency:

Type of Injury Indicated:

Date of Injury:
Name of Medical Provider:
Type of Medical Provider (i.e. General
Practitioner, Orthopedic Specialist):
Date of Medical Appointment:
The Medical Provider has indicated that the  Work Related
injury is:  Non-Work Related
For IME/DME/QME Reviews only: The Medical  Was appropriate for the injury indicated
Provider has also indicated that the medical  Was not appropriate for the injury indicated
treatment provided:

Date Form Completed:

Name of Person Completing Form:

Amazon Workers’ Compensation Specialist or Agency Claims Representative

Amazon Confidential Revision Date: 25 November 2016

NA EHS PARk PROCEDURES: OMR ENCOUNTER FORM – QUICK 4.0 FORMS
REFERENCE

Amazon Confidential Revision Date: 25 November 2016

NA EHS OSHA RECORDKEEPING 5.0 SELF
IMPLEMENTATION

Instructions for Use: This document is intended to be used as a worksheet to aid the site during the
implementation process

1. Safety manager and site leader read and understand the requirements
of the Recordkeeping Program and all supporting documents.

2. Safety manager and site leader (or designee) identify and assign a leader
with responsibility for the Recordkeeping Program implementation.

The leader responsible to implement this program is:

3. Identify the individual that will convert incidents to recordable in Gensuite

and verify the entry on the OSHA 300 Log within 7 days of being aware
the recordable criteria have been met.

The site Record-keeper is:

4. Establish the process to create a “master file” for each recordable and
non-recordable case where medical treatment beyond first aid was provided
and upload these files into the Gensuite I&M. The “master file” shall
include Gensuite investigation, the Worker’s Comp Review Document (if applicable),
recordability rationale information, and relevant claim information as outlined in the
Recordkeeping Program.

The location of the master file is:

5. Schedule the monthly reconciliation meeting with required attendees. Follow

the Monthly Injury and Illness Reconciliation Process and document minutes
using the Monthly Reconciliation Meeting Minutes Template.

6. Train Site Leader / GM on the PARk Process.

7. If the site has a hearing conservation program ensure the record-keeper has
a process to evaluate all hearing tests for recordability.

8. Assess and confirm the site's compliance with this Program.

9. Schedule this site’s Annual Self-Review of compliance against the NA

Safety Programs, to take place during the subsequent quarter.

The next Annual Self-Review is scheduled for:

Amazon Confidential Revision Date: 25 November 2016

NA EHS OSHA RECORDKEEPING 6.0 REVISION
HISTORY

Date Document Changes Actions to Implement

5/2/14 Program New Format to Support
Gensuite
Removed requirement N/A
to log hearing loss case
as recordable prior to
30 day retest
Corrected hearing loss
cases to include 25dB N/A
average
Changed wording to N/A
Recordability Rationale
from Medical
Discrepancy to support
Gensuite
Added weekly and Weekly and monthly
monthly validation of verify I&I accuracy in
I&I log as required Gensuite
under Gensuite
Added checks in the N/A
monthly reconciliation
to verify I&I weekly,
review days restricted/
lost time.
Added notification of Follow Communication
fatality, serious injury requirements
to include Regional
Safety Manager and
EHS Director
Added requirement to Add compliance
complete annual calendar task to
review in December complete
and validate in January
Added Redline Case to Utilize NRJ in event a
NRJ Process case was previously
recorded
Changed wording of N/A
Accuracy form to OSHA
300log
Added Privacy Case Read and understand
Section
Added definitions Read and understand

Amazon Confidential Revision Date: 25 November 2016

NA EHS OSHA RECORDKEEPING 6.0 REVISION
HISTORY

9/30/14 6.4 Updated NRJ Sites to obtain required

documentation documents for NRJ
requirements Process
Reconciliation Form Added boxes to fill in #
of cases
Non-recordable Form Added requirements Sites to use new form
per 6.4 changes
12/19/14 6.1.7 Updated with new Follow Updated
OSHA Fatal / Serious Requirements
injury reporting
requirements, added
details for states,
Added links for
references and FAQ
6.4.4, 6.4.8.9, 6.4.12 Added Follow Updated
Requirements
6..4.7 Updated some lines to Follow Updated
plural Requirements
6.4 Updated NRJ Sites to obtain required
documentation documents for NRJ
requirements Process
Non-recordable Added requirements Sites to use new form
Justification Form per 6.4 changes
Forms Added FAQ for Reference
reporting
6/14/15 6.4.12 + Throughout Adjusted to remove Communicate to sites.
documents OHM as a reference.
NRJs are now
uploading under
Gensuite I&M
6/23/15 6.3.3 Clarified attendee need Communicate to sites
for reconciliation
meeting may be via
phone
7/6/15 6.1.7.2.3 Updated WA reporting Communicate to sites
requirements
11/09/15 6.3.9, form and work Updated to include Communicate to sites
instruction sub-regional safety
managers role in
reconciliation and NRJ
Process
6.4 Updated to describe Communicate to sites
the NRJ automated
work flow in Gensuite
2/28/16 4.3.1 and 4.4.1 Recordkeeping Review with all safety
decisions are made by and Amcare personnel

Amazon Confidential Revision Date: 25, November 2016

NA EHS OSHA RECORDKEEPING 6.0 REVISION
HISTORY

Safety Personnel, not and follow the new

Amcare OMR’s policy requirements
6.4.1 NRJ’s must be Review with all safety
reviewed, approved team members and
and submitted into the follow then new
NRJ approval process requirements.
by the Site Safety Lead.
In their absence, the
Safety Manager will
assign a single Site
Safety Specialist to act
as the proxy for this
role.
11/25/16 Throughout Document Updated all references Follow PARk process.
and forms from NRJ to
PARk, consistent with
the network rollout
calls that have already
occurred.
Added Appendix EHS Quick Reference Reference Only
Guide- PARk
Procedures: OMR
Encounter Form

12/5/16 Throughout Document Headers changed from No field action required

NAFC to NA EHS. Term
“policy” changed to
“procedure”.
Additional checkbox
added to PARk form.
2/1/2017 Throughout Document Updated PARk No field action required
Acronym
2/2/17 Updated document Updated document No field action required
with link to PARk form with link to PARk form

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NA EHS OSHA RECORDKEEPING 6.0 REVISION
HISTORY

31