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Determining What is Recordable to OSHA

Written By Iniesta Estable on Wednesday, March 27, 2013 | 5:26 PM

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 record keeping 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 record keeping 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.