By Stephen Stankavage, Director of Environmental, Safety & Health, PGCA
Greetings, safety fans!
This month I’d like to discuss what makes an injury “recordable”, as in, it must be recorded on the OSHA 300 log. I’ve been receiving many questions about this and I’d thought we could spend this month and next talking a little about it.
First, your best source is the 29CFR1904. However, this can be a little confusing at times so I hope I can clear it up a little for everyone. Moreover you can also find many answers to questions by accessing the following:
OSHA Recordkeeping Handbook
Small Business Safety and Health Handbook
OSHA Primer
Training Requirements in OSHA Standards
(You could also ask Steve! Email him at sstankavage@printcommunications.org or call him at (570) 579-6497)
First the basics:
An injury first must be:
- Work-related
- A new case – otherwise update the old case
- And meet general recordkeeping criteria which equates to
- Death
- Days away from work
- Restricted work or transfer to another job
- Loss of consciousness
- A significant injury or illness diagnosed by a physician or other licensed health care professional
The general recording criteria is the one that most people find difficult to decipher so let’s break them down a bit better.
Death – the most serious and the most tragic of all injuries; must be recorded to include the date of the death and 180 days of lost time. This is also one of the cases where you must call OSHA DIRECTLY within 8 hours of the occurrence and report the incident.
Days away from work – Equates to the employee’s injuries that are so severe that they require bed rest or must remain in the hospital or at home for any amount of days AFTER the day of injury. Days don’t start counting until the next full day.
For example, if an employee is injured Monday morning and the physician tells the employee to take the remainder of Monday and all of Tuesday off, it is recorded as one lost day. However, if the physician tells the employee to take the remainder of Monday off but report to work Tuesday, then it isn’t counted as a lost time injury and may not even be a recordable injury. Now, if the physician tells the employee to report to work on Tuesday but with the following restrictions … The injury is still recordable but not as a lost time, it’s recorded as our next category.
Restricted work or transfer to another job – This type of injury restricts the employee from performing some function of their job, whether it be not standing for long periods, use of a body part, or lifting restrictions, etc. Moreover, if the employee must be “transferred” to another job temporarily because of their injury, it also counts in this category. This category can leave many people scratching their heads.
For example: if an employee restriction is that they can’t stand in place for longer than two hours, but their job is desk work where they sit eight hours of the day, would that be recordable or not? The answer is yes. The reason involves the nature of the injury and what they were doing at the time of the injury. So, in our case, an office worker who can’t stand longer than two hours was injured when she tripped over a garbage can walking to the file archive room to return some files. As walking to and from the archive room is a function of their normal job, the case is therefore recordable.
Loss of consciousness – This one is self-explanatory, but remember, it must be work related. If the loss of consciousness was caused by medications, not work related, or a personal medical condition not a direct result of a workplace injury, it’s not recordable. Loss of consciousness from a heat illness in your shop would be however.
A significant injury or illness diagnosed by a physician or other licensed health care professional – This category generally causes the most confusion. What is a significant injury? Generally, it’s any injury or illness that requires more treatment than “First-Aid”. That includes, but not limited to; broken bones, non-bendable splints, stitches, staples, wound adhesives, IV fluids, prescription medications of prescription strength, and surgeries. You must remember that just because you send an employee to the doctor doesn’t always mean that the injury is recordable. You must look at the treatment that was performed.
Next month we’ll look at some instances that can cause the confusion of “is it recordable or not!” We’ll look at the infamous “employee slipped on the ice in the parking lot case”. The “doctor gave him lost time so we put him on vacation” case. The “they were supposed to come to work but called in said they can’t” case and other side “he was supposed to stay home but came to work anyway” case and many other favorites! Stay tuned! And as always, I am always here to help if you have questions about your OSHA 300 logs.
About the Author: Steve Stankavage has over 25 years’ experience in Environmental, Safety and Health with 16 years’ experience in the printing industry. Steve came from the defense contracting industry but also has EHS experience in heavy construction, wind energy, waste management and academia. He assists Print & Graphic Communications Association members with OSHA inspection assistance, written safety programs and assessments, permit preparation, emissions tracking, forklift training and more. Contact Steve at sstankavage@printcommunications.org or (570) 579-6497.
