The OSHA general recordability criteria are listed in Section 1904.7 of the Code of Federal Regulations (CFR), and every non-exempted employer should carefully review the criteria so that the requirements are followed, but that injuries are not over reported. Over-reporting of employee injuries will create a higher injury rate, and may lead to an OSHA inspection or loss of contracting opportunities with large companies or municipalities that consider injury rates when awarding construction contracts. An injury is recordable if it results in any of the following: (1) death, (2) days away from work, (2) restricted work or transfer to another job, (4) medical treatment beyond first aid, (5) loss of consciousness, or (6) a significant injury or illness diagnosed by a physician or licensed health care professional. Test your knowledge on these twelve events and determine if the employee injury is recordable.
- Is an injury recordable if a worker is injured on Friday and comes back to work Monday? Yes, but only if medical provider states employee should not work or perform restricted work over the weekend (even those are no work days).
- What is the maximum number of days away from work to record? 180 days.
- Do I stop counting missed days if an employee leaves the company? Yes, if he/she leaves for a reason other than the injury (such as term for positive drug test, or taking another job) you stop counting.
- If a doctor prescribes non-prescription medication (over the counter), is that recordable? No. Non-prescription medication should be preferred, if effective.
- Are chipped or broken teeth recordable? Yes, these cases are considered significant by OSHA if diagnosed by a health care professional.
- What about an employee that complains of muskoskeltal soreness or pain from work activity, and company assigns lighter duty? No, if a doctor does not restrict the employee’s job functions (full release) and the doctor only administered first aid and no prescriptions were written.
- Is surgical glue used to close a wound recordable? Yes, surgical glue is a wound closing device. All wound closing devices except for butterfly and steri-strips are by definition “medical treatment,” because they are not included on the first aid list.
- If an employee slips and falls on the way to work on company property, is this recordable? Yes, company parking lots and sidewalks are part of the employer’s establishment for recordkeeping purposes. The event does not meet any of the work-related exceptions contained in 1904.5(b)(2). The employee was on the sidewalk because of work; therefore, the case is work-related regardless of the fact that he had not actually checked in.
- What if 2 employees get into a fight in the company parking lot, and one employee breaks his arm, is that recordable? Yes, the company parking lot is considered the employer’s establishment, and there is no exception for workplace violence events. Even though it happened before work, it is still recordable.
- If an employee bumps his knee and it told by his physician that he may stay out of work until MRI, but later MRI shows no injury to the knee – can this injury be deleted from the 300 log? No, the event met the definition of recordability at the time because the employee had sustained a work-related injury–a bruised knee–involving one or more days away from work. A subsequent MRI result does not change these facts. MRI was not a basis for lining out the entry.
- Which of the following is recordable? X-rays (no, not included in medical treatment); non-prescription medication (no, first aid); non-rigid means of support, such as knee wrap or back belt (no, first aid); removing splinters by irrigation or tweezers (no, first aid); drinking fluids following heat stress (no, first aid); fractured toe (yes, even with no medical treatment because it is significant); burns (yes, if more serious and treated with prescription cream or other medical treatment).
- If an employee’s signs and symptoms (from an injury or illness) disappear for a day and then re-surface the next day, is this a new case? No, an employee has “recovered completely” from a previous injury or illness, when he or she is fully healed or cured. Due to the short time, the evidence supports the fact that the injury was not fully healed. The employer must use his best judgment based on factors such as the passage of time since the symptoms last occurred and the physical appearance of the affected part of the body.
Check out the latest OSHA Recordkeeping Handbook for Employers and review other important interpretations.
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