What is an OSHA recordable case of
injury?
In previous articles,
I talked about OSHA record keeping in regards to job related injuries and illnesses. In this article, I will present guidelines
for what is a recordable case and what is not. You are not required to keep the log for cases which are not deemed recordable.
Recording an injury or illness does not necessarily imply the anyone was at fault or that an OSHA standard was violated. It
also does not imply that the case is compensable under workers compensation laws.
It must first be clear, that record keeping of
injuries and illnesses must be done in good faith. It is the employer who decides what needs to be recorded and what does
not. However, if you are found not to be performing the function of recordkeeping in good faith, you may be found to be out
of compliance.
The OSH Act provides basic information on what is, or is not, a recordable case. It must be noted
that your criteria for recordkeeping must meet the needs of safety and health professionals to determine if a problem exists.
Basically, the Act states the any work related deaths, injuries and illnesses, are recordable, except those injuries and illnesses
that are minor, requiring only first aid treatment and do not involve medical treatment, loss of consciousness, restriction
of work or motion and transfer to different duties.
The decision making process, in regards as to what cases need to be recorded should follow
these steps;
1.
Establish whether the case was work related. Did it happen at work, or was it related to the
work environment. Some injuries may happen over time and can not be determined to have happened at any specific time, but
are none the less recordable. Like a wrist injury that was caused from repetitive motion over a long period of time.
2.
Is the case an injury or illness.
3.
If it is an illness, record it and check the appropriate box for illness on the log form.
4.
If it is an injury, decide if it is recordable based on a finding of treatment by medical personnel,
loss of consciousness, restriction of motion or transfer of duties.
For purposes of record keeping, it does not matter who was at fault, even if the employee
was at fault due to willful negligence. Cases are also recordable in the following circumstances;
1. Discovered
after the employee is no longer employed, for the five year period that would cover the injury or illness.
2. Employee
did not report the case at the time of injury or illness. It becomes recordable when it is determined that it happened.
3. Employee
had a preexisting condition that made them more prone to injury or illness.
4. The case happened
off the premises of the business, but was work related.
Determining if work related injuries are recordable requires you to evaluate if the treatment was medical or first
aid. A one time treatment and any follow up treatment for the purposes of observation for minor scratches, cuts, burns and
splinters, which do not require medical care beyond observation to ensure an infection does not occur, are generally not recordable.
This remains true even if the observation was done by professional medical people. Treatment of 2nd
and 3rd degree burns, sutures, treatment for infection, application of butterfly adhesive sutures, removal of foreign
bodies in the eye, use of hot or cold soaking therapy during second or subsequent visits, positive x-ray results or admission
to a hospital would all generally be recordable.
Types
of cases that are generally not recordable:
1. Injuries resulting while using company recreational
facilities, like ball diamonds, gyms, etc. are not recordable.
2. Injuries on company owned parking
lots are not recordable, unless the employee was performing a work related task in the parking lot.
3. Treatment
of first degree burns.
4.
Application of bandages during first visit.
5. application of elastic
bandages during first visit.
6. Removal of foreign bodies in the eye that are removed
by irrigation.
7.
Removal of foreign bodies from a wound that are simple in nature, like using tweezers.
8. Negative
x-ray results.
9.
Administration of Tetanus shot, if that is all that is done.
For additional information regarding work related injuries and illnesses, contact the U.S.
Department of Labor.
OSHA Compliance & Recordkeeping
by Tom Lynde
Employers subject
to OSHA recordkeeping include all businesses in the private sector who have at least one employee. Volunteers are generally
not considered employees if they receive no compensation. If they are paid something though, they are generally considered
employees. Charitable organizations that employ people to perform tasks, are also required to keep OSHA mandated records.
Employers who had less than 10 employees for the prior year are generally exempt from keeping injury and illness records,
except when a fatality occurs or multiple employees are hospitalized. Some states, however, require that even those employers
must still maintain the log. You must consult your state OSHA office to see if you are exempt from the recordkeeping clause.
Only two forms are used for OSHA recordkeeping in regards to injury and work related illness. The first
one is the Log For Occupational Injuries & Illness (OSHA No. 200) and the second one is the Supplementary Record of Occupational
Injuries & Illnesses (OSHA No. 101). Both of these can be obtained from your state OSHA department or the US Department
of Labor.
OSHA
No. 200 is used to record and classify injuries and illnesses and for noting the outcome of those injuries and illnesses.
The forms are to be filled out with each occurrence and at the conclusion of the occurrence. Employers must maintain
at each establishment the log for all injuries and illnesses that are recordable for that establishment and must maintain
the log for five years following the end of the calendar year. The log entry must be made within six working days from the
event. The log is not required to be maintained for any year in which there is no recordable injuries or illnesses. At the
end of the year a summary must be posted in a conspicuous place that lists the totals from the log, calendar year, establishment
address and must be signed by the responsible person for the log. Even if there were no recordable incidents, the summary
must still be posted with zeros on the totals line. This summary must be posted by February 1 of the next year. Failure to
post the summary and maintain the log are punishable offenses and OSHA will issue fines when an inspection occurs.
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