Understanding and Applying the Definition of an OSHA Recordable

What is an OSHA Recordable?

“OSHA recordable” is a term for injuries and illnesses that must be reported to the Occupational Safety and Health Administration (OSHA) on a Form 300 (Log of Work-related Injuries and Illnesses). It includes a work-related injury or illness that results in any of the following:

1. Medical treatment beyond first aid
2. Loss of consciousness
3. One or more days away from work following the date of the incident
4. Restricted work or transfer to another job
5. Any significant injury or illness diagnosed by a physician or other licensed health care professional
6. Any work-related fatality

Employers with ten or fewer employees throughout the previous calendar year are exempt from routinely keeping injury and illness records. (See Standard 1904, “Recording and Reporting Occupational Injuries and Illnesses.”)

Maja Jurisic, MD, CPE, vice president and medical director of strategic accounts for Concentra, presented a webinar to help employers become more familiar with OSHA recordable incidents. The webinar can be viewed online.

Putting Concerns to Rest

“The intent of the recordability standard is focused on creating and maintaining a safe work environment. It requires employers to maintain accurate records of injuries and illnesses and report fatalities, and to make those records available to the government and to employees and their representatives so that we can have safer and more healthful working conditions,” Dr. Jurisic explained in the webinar.

“Maintaining these records doesn't mean that the employer or the employee was at fault in an injury or that an OSHA rule was violated. It also doesn't mean that the employee is necessarily eligible for workers' comp or other benefits just because there was an injury. Injury and benefits are not necessarily synonymous,” she added.

First Aid as an OSHA Recordable Threshold

Work-related injuries and illnesses with treatment limited to first aid are not OSHA recordables. There are 14 treatments that are considered first aid. They are:

1. Use of medications, as long as they are non-prescription at non-prescription strength
2. Tetanus immunizations
3. Cleaning, flushing or soaking wounds on the surface of the skin
4. Applying a wound covering, such as an adhesive bandage, gauze pad, or butterfly bandage
5. Applying heat or cold
6. Non-rigid means of support, such as elastic bandages, wraps, or non-rigid back belts
7. A temporary immobilization device (usually for transport to a hospital)
8. Drilling a fingernail or toenail to drain and relieve pressure
9. Draining fluid from a blister
10. Using an eye patch
11. Removing a foreign body from an eye without using instruments (a swab or irrigation may be used)
12. Removing splinters or foreign materials from other parts of the body using irrigation, tweezers, or swabs
13. Finger guards and first aid massage
14. Drinking fluids for relief of heat stress

In cases of musculoskeletal injuries, there are four actions that are considered first aid (not medical treatment). When treatment is limited to these four treatments, the musculoskeletal injury is not OSHA recordable. They are:

1. Flexible taping
2. Physical or occupational therapy evaluation
3. Instrument-assisted soft-tissue mobilization
4. Exercises to help prevent injury

Loss of Consciousness is OSHA Recordable

If an employee loses consciousness due to a work-related cause or exposure for any length of time, the incident becomes OSHA recordable.

Examples of loss of consciousness that would not be considered work-related and, therefore, not recordable, would include instances when loss of consciousness is solely due to an employee’s personal health condition (epilepsy, diabetes, or narcolepsy, for example).

Also, if an employee loses consciousness during voluntary participation in an activity at work, such as donating blood or recreational activities, that would not be considered OSHA recordable. If the employee is injured as a result of losing consciousness during voluntary activities, the injury is not considered work-related.

Days Away, Restricted, or Transferred (DART)

Days Away from Work

When counting days away from work, start counting the day after the work-related, recordable injury or illness.

“It’s our goal to avoid medically unnecessary disability whenever possible. Concentra clinicians are instructed to treat an injury with first aid, if they can appropriately do so. This is the right thing to do for the patient. We know from the medical literature that keeping people’s lives and activities as normal as possible is the best way to promote recovery,” Dr. Jurisic said.

Based on the licensed health care professional’s recommendation, here are the appropriate responses:

Clinician recommends days away from work, but employee goes to work anyway -> Once a recommendation by a licensed health care professional has been made (and accepted) for days away from work, you have to count and report them on the 300 log, even if an employee decides to go to work.

Clinician recommends the employee return to work, but the employee stays home -> Those days do not count and are not reported on the 300 log as days away from work.

Two licensed health care professionals see the employee and provide different recommendations -> The employer has the right to select whichever recommendation appears most authoritative. Whether days away from work are recorded depends on the recommendation the employer accepts.

Both weekend days and weekdays count, even if the employee was not scheduled to work. Employers can stop counting and reporting days away from work when a cap of 180 days is reached or if the employee leaves to take another job, retire, or for any similar reason.

Work Restrictions

An injury or illness is recordable if it involves restricted work or transfer to another job.

An employee is said to be on “restricted work” when he or she is unable to perform one or more routine functions of the job, beginning on the day after the injury or illness occurs. A routine function, according to OSHA, is one the employee would normally perform at least once a week. Restricted work that is limited to the day of the injury or illness is not OSHA recordable.

“A case that involves restrictions that do not affect a routine function does not need to be recorded, but employers often do record it. To help employers, we instruct our clinicians not to write restrictions that don’t affect the employee’s routine job duties. We enter that type of activity as ‘Patient Instructions,’ instead,” noted Dr. Jurisic.

Significant Illnesses and Fatalities

Although many significant illnesses or injuries will involve the prerequisites for an OSHA recordable that have been described already (treatment beyond first aid, loss of consciousness, days away from work, restriction work, or transfer), there are cases when a significant injury or illness will involve none of these. Even so, these significant illnesses and injuries also are OSHA recordable and must be reported on the 300 log.

“OSHA regards cancer, chronic, irreversible diseases, fractured or cracked bones, and punctured eardrums as significant, and these have to be recorded at the initial diagnosis event, even if medical restrictions, work restrictions, and medical treatment are not recommended,” Dr. Jurisic said.

In all cases, a work-related fatality is an OSHA recordable and must be reported within eight hours.

Watch Our OSHA Recordables Webinar

The best way to learn and share information about OSHA recordability is to watch our webinar featuring Dr. Maja Jurisic. You can also explore our Resource Center for resources that can help you with all of your occupational health care needs and injury prevention.