Deluxe Corporation (DLX) Earnings Call Transcript & Summary

All right. So welcome, and thank you all for joining our session today. I'm super excited to welcome you to our training on OSHA reporting and recordkeeping requirements. Now before I jump in, I'll go ahead and introduce myself. So my name is JJ. And over the course of my HR career, I've primarily worked as an HR Generalist, but Jack of all trades, master of 2 things, workers' compensation and OSHA reporting and recordkeeping. I've also actually served as a defective safety officer during that time, and I completed my OSHA 10 for General Industry. As far as industry experience, I've primarily worked in manufacturing, construction and higher education, but that's enough about me. Let's get started. So first, I'll just address some quick housekeeping items. So we will e-mail you the recording of this presentation and the slides within 24 hours. And I'll also hold a poll later on. And I'd really love for you to participate, but of course, no pressure. And I also want to remind everyone that our session was originally scheduled for 30 minutes, but it has been extended to 60 in order to provide you a deeper dive into all things, OSHA reporting and recordkeeping, but do feel free to jump off if you need to because we will have the recording to now. Now finally, please feel free to use the Q&A box for any questions you have during the session. And at the end of our time together, I'll try to answer as many questions as I can. Okay. So let's go over the agenda. Now I'm well aware that OSHA isn't usually everyone's favorite topic. But no worries if it's not, I am going to make this session as painless as possible. So first, we'll start with a brief overview of OSHA and then we'll dive into OSHA reporting, which is required for all employers and then after that, we'll spend most of our time just discussing OSHA recordkeeping, and that's going to include who's covered by this, what needs to be maintained as well as we'll look at each of the forms individually. And last but not least, we will discuss OSHA's new-ish electronic submission requirements so that we're all familiar with them. Okay. So starting with our overview. Now I do want you to keep in mind that I'm primarily going to focus on general OSHA information that usually is the most relevant to HR However, OSHA has many other requirements that we won't address today, such as workplace poster requirements, industry-specific safety standards, so this is a great reason to actually establish a working relationship with your nearest OSHA as they can help with a lot of those questions. And I do know that contacting OSHA can sound a bit scary to some. But just keep in mind, ultimately, we're all striving for the same goal and that's just to ensure a safe and healthy workplace for all of our employees. Okay. So let's briefly go over the basics of OSHA. So the Federal Occupational Safety and Health Act of 1970 or the OSH Act is administered by the Occupational Safety and Health Administration, which is Federal. The Act does cover private sector employers and their employees in all 50 states in most U.S. territories and jurisdictions that are under federal authority. Now the act ultimately assigns OSHA 2 regulatory functions. So the first one being setting standards and the second being conducting inspections. And this is to ensure that employers are actually following through with providing a safe and healthy workplace. Now in areas where OSHA hasn't provided a specific standard that's addressing a specific hazard. Employers are actually responsible for complying with the Acts general duty clause, and you can think of this as the catch-all clause. So it just says each employer needs to furnish each employee with a place of employment that's free from recognized hazards, and that are causing or likely to cause death or serious physical harm. So the Act does also grant employees some really important rights that you want to be aware of as an employer. So they have the right to file a complaint with OSHA about any safety and health conditions or concerns within their workplace and employees have the right to participate in OSHA's workplace inspections. Now another one to keep in mind is that any employee that exercised any of those rights are protected from employer retaliation under this Act. So it's really important that you're addressing these concerns when they come up to prevent that employee from exercising those rights. Okay. So as I mentioned earlier, OSHA has 2 main requirements that are usually going to fall into the realm of HR. So reporting and routine recordkeeping. Now I'll provide an overview of both for now, but don't worry, we're going to touch on these in much greater detail a little later on. But to start, reporting requires us to contact OSHA directly. So after a certain severe workplace injuries, this is their requirement to contact OSHA. So this requirement applies to all employers if you have one or more employees. In contrast, OSHA also has the routine recordkeeping requirements, and this is required internal recordkeeping and it's for particular types and sizes of employers. Now for recordkeeping, employers that have more than 10 employees are covered by that requirement. And that is unless their industry is exempt as low risk. So in essence, what that means is an employer could be exempt from reporting, but an employer will never be exempt from the reporting requirements. Now OSHA's electronic submission rule also requires that some records are provided to OSHA online, and that's for particular employers as well. And we'll talk about that later. And I always recommend for employers to designate someone within your company that's going to take charge of the OSHA reporting and recordkeeping requirements. And this is because if there is an incident, you don't want to have confusion about who's going to handle these very critical and very time-sensitive compliance task. Now keep in mind that recording or reporting doesn't mean that the employer or the employee was at fault, it also doesn't mean that OSHA rule has been violated. And it doesn't automatically mean that the employee is eligible for workers' compensation benefits. Okay. So as a really important notes, the OSH Act is a federal regulation and OSHA is a federal agency. However, employers may actually be covered by an OSHA approved state plan. So this is the case for private employers in 21 states in 1 territory, which happens to be Puerto Rico. And the Act actually encourages states to go ahead and develop and operate their own safety and health programs. And Federal OSHA's role is to approve and monitor the state plans. And they operate ultimately under the authority of state law. So states that have an OSHA approved plan do need to set standards that are at least as effective as the federal, but of course, they can be more generous. So if you are covered under a state plan for OSHA reporting just make sure that you contact your local state agency as opposed to the federal. And for OSHA recordkeeping, a few states do have specific requirements that will go beyond the federal. So you want to make sure you are aware of those requirements as well. So as an example, California and Oregon have their own state plans, and they also actually have their own required OSHA recordkeeping forms that are different from the federal. Okay. So done with the overview, let's get into our deep dive into reporting. All right. So probably wondering who's covered by these requirements or recordkeeping, well, it's pretty simple. So as I previously mentioned, all employers under OSHA's jurisdiction must report certain workplace injuries. And it's really important to remember, this is true even if an employer is exempt from recordkeeping requirements and reporting is required regardless of your employees' employment status, length of employment or even their employment classification. All right. So now here's the list of what must be reported so employers are required to report any work-related fatalities to OSHA within 8 hours of finding out about it. But keep in mind, only fatalities that occur within 30 days of that work incident must actually be reported to OSHA. Additionally, any type of inpatient hospitalization amputation or eye loss must also be reported to OSHA, but that is within 24 hours of learning about it. And these incidents only need to be reported to OSHA if they actually occur within 24 hours of that work-related incidents. As far as definitions, OSHA defines inpatient hospitalization basically has a formal admission to the inpatient service of a hospital, clinic for any type of care or treatment. Now there are some exceptions to this. So treatment in an emergency room only is not reportable. And you don't have to report an inpatient hospitalization that involves only observation or diagnostic testing. Also keep in mind, if your state has its own approved OSHA plan, you want to double check these local reporting requirements, just in case there are shorter reporting time lines or even additional instances that need to be reported. All right. So now that we know what actually needs to be reported, let's just chat about the list of items that don't actually need to be reported. So these are typically going to include incidents that result from a vehicle accident. There is a caveat for if it occurred in a construction work zone. Also incidents that occurred on a commercial or a public transportation system. And then hospitalization that results in only diagnostic testing and observation, as I mentioned a bit earlier, as well as those incidents that occur outside of the reporting time lines that we just reviewed on the previous slide. Okay. So we now know what to report and what not to report directly to OSHA. Now when it comes to where to actually report this information, you essentially have 3 options for reporting you can either call the nearest OSHA area office or you can call the 24-hour OSHA hotline. And keep in mind, if you have a state plan, you'd want to call your local option or office and then the last is you can submit an online report on OSHA's website. Now as you can see, the links on this page are clickable, so when you receive the slides, you'll actually be able to click on these and go to the website and see how all of these recording functions work and how they look. Now if you do ever need to call in an incident, just be prepared to have that relevant information handy, and that's usually going to include who was involved, the type of reportable event and a brief description of the incident and what happens. All right. So we're going to switch things up for a bit and jump into a poll here. So our poll question of today is, what is your current role in managing health and safety for your workplace. Now everyone's organization is going to be different so if you don't see an answer that exactly fits, just pick the closest option. So I'll go ahead and launch our poll, one moment.

And I'm behind the scenes helping J.J., for some reason, it's not letting me launch. If you want to give that a try, we'll just wing it here. Thanks, everyone, for your patience.

Yes. And I am seeing participation. Awesome, thank you so much. I love it. Okay. So I'm going to give about 10 or more seconds for everyone to get their response in. So I'll go ahead and close our poll and let's see the results. Okay. So we have a good bit of people that are currently doing some level of OSHA reporting, recordkeeping and a little bit of standards as well. But those of you that don't currently have a role in this, it is still good information to have. So thank you, everyone, for your participation, I go ahead and close this out, and we'll get right back to our content for today. Okay. So now we're going to do a deep dive on OSHA's routine recordkeeping requirements. So under OSHA's recordkeeping regulation, there are certain covered employers that are required to prepare and essentially maintain the records of any type of serious occupational injury or illness. So this information is really important for employers, workers and OSHA when it comes to evaluating the safety of a workplace understanding industry hazards and even implementing worker protections. So you'll notice all 3 of the forms listed are required and for any covered employer and we will go over those individually in just a bit. But altogether, the purpose of these forms are to assist both the employer and really OSHA in developing a full picture of the extent of -- and even the severity of work-related incidents. So you'll notice I've listed these forms in a particular order that is on purpose. This order is the order you would complete the actual form. So first, Form 301, then Form 300 and then Form 300A. And it's also really critical for me to mention that Forms 301 and 300 actually build upon the information that will be included on 300A. So in other words, your Form 300A is wholly contingent on that information that you input on Forms 301 and 300, but again, we'll look at these forms in a couple of slides, then hopefully connect some dots for everyone. Now with that said, while these are required forms, technically, employers can create their own, so you can do so. But if you do so, they have to be equivalent to the federal forms. So as long as the forms have the same information and they're completed using the same instructions as the OSHA forms, that is fine to do. So for example, many employers will actually use their workers' compensation insurance form instead of the 301 incident report or sometimes we'll also see supplementing an insurance form by adding information that's required by OSHA. Now I do want to also remind everyone that it is really important to distinguish that OSHA injury and illness requirements and workers' compensation are independent of each other. They're not mutually exclusive. Sometimes, they are, but not always. Okay. So starting with employers with 10 or fewer employees. So generally, if you fall into this category of having 10 or fewer employees at all times during the previous calendar year, then you wouldn't need to keep OSHA injury and illness records. Now there's a caveat to this that is unless OSHA or the Bureau of Labor statistics informs you in writing that you do need to keep records. Now I do want to note that this exception for size is based on the number of employees in your entire company, not just a single work location. So to determine if you are exempt based on your company size, you would need to determine your company's peak employment. And that just means the time frame in which you had the most employees on your payroll during that last calendar year. And if you didn't have over 10 employees at any time in the last calendar year, then your company qualifies for the partial exemption and are not required to maintain the records that I'll be going over in this section. Okay. So now let's chat about employers that have 11 or more employees. So they are required to maintain records unless their industry is exempt due to being low risk. Now routine recordkeeping is required and this really just means that you are regularly performing this procedure, and it's not just something that you can do at the end of the year, for example, you need to, throughout the year, as things happen routinely record. Now for businesses in a low-risk industry, and this is regardless of size, employers do not need to keep records. And again, that's on less OSHA or the Bureau of Labor Statistics ask you to do so in writing. And the list of exempt industries is actually classified by the North American Industry Classification System, also called NAICS, which I'm going to call it because it's quite a long acronym. So if you're not sure about what your NAICS code is, you can find it either online or you can contact your OSHA office or you can even contact your workers' compensation carrier because they typically will use the same coding system when they are assigning risk to particular industries, so they can be really helpful, too. Now the exempt or the list of exempt industries is pretty long and includes over 80 industries. So I'm not going to go over all of those, but I will give a couple of examples so you can get an idea. So eating and drinking establishments, certain types of retail stores, certain service industries. So personal and business services, medical and dental offices, legal and so on and so on. Now this partial exemption that's based on the industry classification and risk applies to individual business establishments. So what that means is if your company has several business establishments that are engaged or performing different classes of business activities than some of your company's establishments may be required to keep records while others are actually exempt. Additionally, you do want to refer, as always, to any applicable state laws as these can differ as well. Okay. So before we get into our recordkeeping forms individually, I do want to just cover how to determine if an injury or illness is recordable. So if you're like me, you love a visual, this flow chart provides a good high-level overview of the steps in determining whether an injury or illness is actually recordable. So I like to highlight this middle column. So all 3 of these, these are the key things in determining if an incident is recordable. So was the injury or illness work related? Is the injury or illness a new case? Or was it severe enough to meet OSHA's recording criteria. So the keywords here are work-related, new case and severe. Now I know you may be wondering, how do I even know if it's work related or severe. I'm going to go right into that. So work related in this context essentially means that if the event or the exposure that happened in the workplace, was caused by or even contributed to that resulting condition could be recordable. Also, if something is significantly aggravated such as like a preexisting injury or illness that could also qualify, which sometimes surprises employers. Ultimately, work relatedness is presumed for injuries and illnesses whenever they're resulting from any events or exposures in that work environment. And of course, that's unless an inception applies. But keep in mind, the burden is ultimately on the employer to prove that an injury was not work related. So it is really important to have some good documentation. Now there are situations when an injury or illness that occurs in the work environment isn't actually work related and therefore, subsequently is not recordable. And a couple of examples are if an employee comes into their typical workplace, but they're actually only a member of the public that's not going to be recordable if there is an incident that results from a voluntary participation in activity, so that could be like if your company has a wellness program and you have donating blood or getting a flu shot or even if you have a recreational activity like exercise classes at lunch or a company's sports team. Those are usually not going to be recordable. Now if the incident is solely the result of an employee doing a personal task that's unrelated to their employment or if it's the result of an employee eating, drinking, prepping food or even drink for personal consumption, also likely not going to be recordable and an example of this would be if you had an employee that was injured by choking on the sandwich at lunch, while they're in your establishment, that's not work related. So injuries and illnesses that are intentionally self-afflicted are also not going to qualify as recordable. Okay. So now on to that general recording criteria. So employers must record any work-related injury and illness that results in the following. So death, days away from work, any type of restricted work or even a job transfer, any medical treatment that is beyond first aid, any type of loss of consciousness and any significant work-related injury or illness that would be diagnosed by a medical professional. Now employers don't need to report a number of these incidents. So if there's a visit to a medical professional and it's only for observation and counseling, don't need to report that, if there's diagnostic procedures, so think about an x-ray or blood test. And then if there's any temporary immobilization devices, while you're transporting an accident victim, so something like slit, slings, net collars, backboard. There's actually a full list that defines first aid and you'll be able to take a look at that. And I recommend having that handy just so you're careful not to over record and there's a lot of reasons why you don't want to over record. A lot of times employers think, well, let me just put it on there just in case. I don't recommend that. OSHA doesn't love it either. All right. So now we're going to go ahead and start looking at these 3 forms individually. So I'm going to give a disclaimer that I know we're talking about a lot of forms and numbers, and they can get really confusing, especially if you haven't done this before, but I'm going to try to break it down to really the important pieces of each of these forms. Now the form you see on the screen is part of the federal forms, it is a fillable PDF file, and it includes really detailed instructions. I actually really love this packet. It is super helpful. But OSHA does also provide an Excel version of the forms, if you prefer that instead. Now looking at this Form 301. As a reminder, this is the injury and illness incident report. And this is the first form you would fill out once you know, okay, I have a recordable work-related injury or illness. Now this forum does have to be completed within 7 calendar days after you actually receive the information, and you do need to fill out either this form or an equivalent as mentioned earlier, that contains all the same information. So as you can see, this form includes quite a bit of information. It's all about the employee that was evolved in the incident information on what type of healthcare they received and also information on the case. So the date, time, nature of the injury or illness and even how the incident occurred. So once this form is completed, you do want to make sure that you're maintaining it in a separate injury and illness file, it cannot be in their personnel file for confidentiality purposes. Okay. So now looking at Form 300. So this is the log of work-related injuries and illnesses and this is where you'll list each recordable case and note the extent and the severity of each of those incidents. So in other words, when an incident occurs, this log is just going to be used to record specific details about what and how the incident happened. And this form also must be completed within 7 days of that incident being known. Now do keep in mind that if you're an employer that has multiple establishments, you do have to have a separate OSHA 300 log kept at each one that is expected to be in operation for at least a year or longer. And this log is maintained by the employer. So this should not be posted in your workplace because it does have very specific information to specific employees. Now in the following slides, I'm going to go over the specifics of this form in greater detail by step by step to make it a little bit easier to digest. Okay. So still on the OSHA Form 300, but for steps 1 and 2. So the first step is pretty easy. You're just identifying the person with their case number, employee name and their job title. Now when it comes to step 2, this is where you're actually describing the case. And you want to keep in mind that you want to be very specific on this form. So for example, as far as where the event occurred, you don't want to be too general because OSHA really does not like that and you don't just want to list the department name or a state like workplace, you want to be specific as to the location. So for example, front office reception is desk is very specific. And when you're asked to describe the injury or the illness, it's not going to be enough to just stay cut to the hand. Instead, you would want to state something like cut to the right thumb caused by a box cutter. And there are a few situations when employers would not want to list or may even not be able to list an employee's name on the log due to privacy concerns and OSHA has a really great instructional guide for if this is the case. They have a full list of instructions and pieces that are privacy that you wouldn't want to put their name. All right. So for steps 3 through 5. Step 3, pretty self-explanatory. You're just classifying the case. And keep in mind that you're choosing only 1 and it's the most serious outcome of the case is how you're going to classify it. This PDF form won't let you pick more than one. So it's -- we'll stop you. You won't be able to. And then for step 4. So both of these columns are referencing, entering the amount of days that an employee was away from work or that employee was transferred to another job or if they had some type of restricted [ duty ]. So restricted work is defined as a medical provider recommending that an employee not perform at least 1 or more of their routine functions of their role or if they recommend that they don't work their full schedule workday, so like a reduced schedule. Now for recordkeeping purposes, and employees routine functions or work activities that the employee regularly performs. And this has to be at least once a week. So if I have -- if I experience an injury, let's say, and I'm restricted from lifting anything over 50 pounds, but I normally only lift 20 pounds in my position, then I didn't actually have any job restrictions, and you wouldn't need to record that. Okay. So a big question I typically get is, how do I count these days. So I have a couple of tips for counting days away from work and transfers and restricted jobs. So to start, you want to begin counting days on the day after the injury or illness. So the actual date of the injury illness doesn't count. And if you have an employee that's out or restricted for an extended period of time, what you would do, you would enter an estimate of the days that the employee will be away. And then keeping in mind, you can always come back and update that count when it's actually known what number of days they were out. Also, all calendar days are counted here for the purposes of accounting days. So this includes holidays, weekends, vacation, et cetera. And this count is not based on the employee's actual schedule of Workday, so calendar days. Also, you may actually cap the total days to 180 and that's going to be combined between the days of missed work and days of restricted duty. So if you had someone out for 200 days, it doesn't matter, you can just put 180 for the purposes of the recordkeeping. Also keep in mind that recordable incidents do not cross over years. So when it comes to reporting and even counting days, an incident is only recorded once. So for example, if I have an employee that's injured on December 1 of this year, and they're out of work until February 1 of next year, you would only record the incident on the 2022 log because that's when the incident actually occurred. So you may have to go back and update the time line that they were out of work, but you wouldn't record it on your 2023 log, for example. Okay. So now moving on to the 300A form. So this is a summary of work-related injuries and illnesses and this form shows all of the work-related injury and illness totals for that year, and it's based on each category. So when you're using the 300 log, all you want to do is count the individual entries that you've made in each of these categories, and then you're going to write the totals there. Now if you had no cases, it's really easy, just write 0. Next, in the box to the right, where that's establishment information, this is where you're going to enter the calendar year that is covered as well as your company information, the annual average number of employees and the total hours worked by all of the employees that are covered by that 300 logs. Finally, the information must be certified and this sounds simple and straightforward, but it actually isn't -- and it catches a lot of employers off guard, and we're going to discuss in detail who can complete these forms on our next slide. Otherwise, this form does need to be posted in a visible location from February 1 through April 30 of that next year. So this is -- or the purpose of this is really just for employees to be aware of any injuries and illnesses that are happening in their workplace. And of course, after April 30, you can take the 300A down, but you do have to keep it for at least 5 years after the year that it pertains to. Okay. So as I mentioned, Form 300A employer certification. So only a company executive can certify that they've examined 300 logs and that they believe the annual summary is correct and complete. So as far as who's considered a company executive, the list is pretty short. So an owner of the company, but that's only if the company is a sole proprietorship or a partnership, otherwise, an officer of the company or the highest ranking company official that's working at that establishment or the immediate supervisor of the highest ranking company official that's working at that establishment and that's it. So if you're not one of those employees, you can't actually certify the 300A before it's posted in the workplace. And as a reminder, you do need to post a copy of the 300A in each establishment. And it has to be in a visible place where notices to employees are typically posted, so you don't want to hide your 300A form. You want employees to be able to access it easily. All right. So as far as retention requirements. So employers do need to maintain these records for 5 years, and that is following the end of the calendar year that the records are covering. Now somewhat surprising, during this retention period, employers do have to update their stored OSHA logs with any newly discoverable recordable injuries or illnesses and show any changes that have occurred in the classification of those previously recorded incidents. So if the description or the outcome of a case changes, you would need to remove or outline the original entry and then enter the new information. Now employers are not required to update the 300A summary or 301 reports during this period. But of course, you could do so if you want it to. Really, it's only the 300 log that you would be required to update. All right. So as I had previously alluded to, OSHA in the not-so-distant past actually issued some rule changes that will require electronic submission of certain records for some employers, and I'm going to go ahead and start discussing those now. So first, I want to address the purpose behind this requirement. So OSHA states that they're taking in this information because employers are one already required to collect it. And two, they want to use the data to ultimately increase worker safety and to make everyone informed of workplace hazards. Now OSHA does release this information on their website. So OSHA believes that by doing so by releasing the data, they're ultimately encouraging employers to increase their efforts to prevent worker injuries and illnesses. Also, OSHA is really trying to nudge employers to increase their workplace safety so that because it's publicly available, so you can see the record. And this is intended to enable researchers to be able to look at the data and then identify any workplace safety hazards before it becomes widespread. So keep in mind, OSHA does post the establishment specific data on its public website, which is just OSHA.gov in case you want to peruse, but only aggregate reporting is shared. So OSHA sanitizes the information in accordance with federal privacy laws. And I will say this rule has seen many challenges to it. But from my view, I think it's really important to create more awareness and workplace safety. And the goal is to potentially decrease injuries, illnesses and quite honestly, save lives. And so if that's not reason enough, then preventing these incidents before they actually happen can also very much save an employer's bottom line, i.e. money in the long run. Okay. So now you may be thinking, is my business required to do this electronic reporting. So it depends. So establishments that have 250 or more employees that are currently required to already keep those OSHA records, do need to submit their 300A only summary online. So the same exemptions for low-risk industry and for NAICS codes are going to apply here as well. Additionally, establishments that have 20 to 249 employees that are classified in particular industries that have historically high rates of injuries and illnesses are also required to electronically submit their 300A. And this is where it gets a little bit confusing because it's another list to look at and consider. So if you're on that list, then you must report records electronically. If you're not, then your industry is exempt based on classification of low risk. So special note for those with state plans, the states do have to adopt requirements that are substantially identical to the federal but states can choose to either use the Federal OSHA Collection website or they can create their own site. So unless you hear otherwise from your state plan, you'll want to report your 300A online if you're required to do so as stated previously, so 300A, online, federal, if the state plan doesn't require you to do otherwise. Now as far as where and when to actually report this information. So every year, any covered establishments do need to submit their 300A by March 2 of each year. And OSHA has provided a secure website, which you'll see is a clickable link here once you get the handouts. And there are 3 options for submitting this data. So you can either do a manual data entry via a web form. You could also do a CSV upload or you could do an electronic transmission of the data if you are already using an automated recordkeeping system. All right. So I want to give all employers and you all, a really good pro tip. So when it comes to really all things OSHA, OSHA has best kept secret that they don't necessarily want to be a secret, but consultative services, this is critical for every employer to contact OSHA to be able to get this no cost. So this is a completely free service for small and medium-sized businesses to actually engage with a consultant, and this is not enforcement. So they're not coming to do an inspection and write it up for violations. They're actually just coming in to help you identify workplace hazards, provide any advice on compliance and especially OSHA standards, and they will also assist you with either establishing or even improving the safety and health programs. Now consultative services. The answer is quite a bit of questions each day. So they have a lot of expertise in different industries. And some states also offer telephone consultations. So that works well for if you don't have a work site. So if you have remote workers for instance, and you wanted to get some consultative services for your traveling employees. That can be really helpful, too. And I do have a link here where you can click to see the federal consultative services website, but you will also have contact information so that you can get to that state's website. Or even if you honestly, Google or well, I won't be search engine specific. But if you type in and try to get to the state and then consultative services, it should pop up as well. And like I said, this is really helpful. And as far as relevancy to this presentation, the biggest benefit I have seen, and I've personally used consultative services more than once is that they'll look at your OSHA logs, and they'll tell you, "Oh, you overreported here or maybe you should be more specific here." So I'll be honest, consultative services is why I know a lot of this information because I've had them come in, look at my OSHA logs and they've given me guidance. So I am a big, big promoter of using consultative services, especially if you are in high-risk industries, like I said, they're separate from enforcement. So they're not going to run back to the state agency and say, "Oh, my goodness, I found all these violations." They're going to help you to fix those essentially. All right. So we have made it through. I do appreciate everyone listening to me over the last 50-ish minutes and I do really hope that everyone is leaving today with at least some refresh or some even new information to take back to your business. Now you're welcome to jump off if you need to. But as I stated previously, I'll go ahead and go over some of the Q&A and answer some questions since we have a little bit of time left. Now just give me a second so that I can take a look at our questions. All right. We have quite a bit of questions. I really appreciate all of the participation. So a good one that I love to answer is, so the question is, "can you talk a little bit more about privacy claims and when we need to exclude the name on the OSHA log." So this is a really great question. it doesn't come up a whole lot, but some examples of when a privacy claim would occur would be if someone has an illness or injury that's related to an intimate part of their body or their reproductive system, you would not want to put their name. Other reasons are for injury or illness that results from like a sexual assault or mental illness, a case of HIV infection, hepatitis, tuberculosis, kind of those communicable diseases and then also the needlestick injury. So if you're cut by a sharp object, you would not want to put their name. And then there are some other reasons as well, like I referenced, there is a really good list, which you'll be able to access. And then as far as what to actually do. So you're not entering the employee's name on the OSHA 300 log. So you would just enter privacy case in that name spot. And then you would keep a separate confidential list of the case numbers and the employee names for each of your establishments so that you know who that case belongs to in case you need to go back and update that information or if OSHA or regulatory agency ask you for that information. So thank you for that question. That is a very common question, but it doesn't come up a whole lot, thankfully. Let me see if we have another. Okay. So the question is, "if I obtain employees from a staffing firm, do I have to record an injury or illness that happens to one of those employees when they're working in my workplace." So employers are generally required to record any type of recordable injuries or illnesses for any employees that you're supervising on a day-to-day basis. So even if they're not on your payroll technically, if you're supervising them day-to-day, then you are responsible to put that on OSHA log. So just keeping that in mind. All right. Let me see if we have time for one more, okay. All right. This is a good one. So what about preexisting health issues. So if someone has heart condition or if they have a heart attack at work or anything along those lines. So is that recordable? The answer is it depends. So you have to think about was that preexisting health condition actually made worse, aggravated or -- or sorry, wasn't made worse at work. If it was, then you would need to record that. Now if you have symptoms that are just kind of arising out of the work environment, and they're not actually due to a work-related event or exposure. Then probably, it's not work-related, but you just want to keep in mind those criteria. So is it work related? Is it CRE or severe? And is it a new case. So keeping those in mind. All right. So let me see we still have a little bit of time. So let's me just see if we have one more. All right. "So do we record an injury that was denied by the workers' compensation carrier." So this is another "it depends". So keep in mind, workers' comp and OSHA recordkeeping, two separate things. So they have 2 separate criteria. So like I mentioned earlier, OSHA is going to be looking at, was this aggravated, was it work related? Is it severe, all of those things. So you still want to abide by OSHA's criteria to determine if a case is recordable. So being denied by the workers' comp carrier is not an automatic, no, you don't get to record or you don't have to record. So okay. So we are getting towards the end of our time. So I do just want to thank you all again for having such great participation. I see quite a few questions. And I just so much appreciate you all, and I hope you have a great rest of your day.