Recordkeeping Conundrums

Recordable v. First Aid and Injuries that Require Reporting in 24 Hours

OSHA recordkeeping requirements can be a source of stress to company representatives that are designated to maintain the OSHA 300 logs.  In some cases, it is assumed that because an injury is covered under worker’s compensation that it must also be recordable. This is not necessarily true. So how does OSHA define what is considered First Aid, and therefore not subject to the recordkeeping requirements?

If a medical professional prescribes the use of a non-prescription medication to be taken at non-prescription strength, the case is first aid.  If the medical professional gives instructions to the injured associate to use a non-prescription medication at prescription strength e.g., taking four 200 mg. tablets (the size of an M&M) of Advil, then the case is considered recordable because use of a non-prescription medication at prescription strength is considered medical treatment by OSHA. 

The same applies to a job restriction issued by the employer, such as no lifting/carrying materials over 10 pounds, when the medical professional has released the employee to perform his/her normal job duties. The employer is required to record that restriction under the Job Transfer or Restriction column of the OSHA 300 log.

Tetanus immunizations, and cleaning, flushing, or soaking wounds on the surface of the skin is also first aid.  Most people do not stay current on their tetanus immunizations, so an exception was made for this vaccine.  Other vaccines like the Hepatitis B vaccine or rabies vaccine are medical treatment.

Wound coverings including Steri-Strips™, butterfly bandages, Band-Aids™, gauze, and other bandages are all considered first aid. Use of wound closing devices such as Dermabond™ glue, stitches, and staples are all medical treatment. 

Use of non-rigid supports such as elastic bandages, wraps, and non-rigid back belts is considered first aid. Temporary immobilization methods for transport of an injured associate such as splits, slings, neck collars, back boards, etc. are considered first aid, as a medical provider has yet to determine if continued use for treatment will be necessary. The use of devices with rigid support issued by a medical provider and intended to immobilize parts of the body are considered medical treatment.

Hot or cold therapy, drilling of finger or toenails to relieve pressure, using eye patches, draining fluid from blisters, and removing foreign bodies from the eye using swabs or irrigation are all considered first aid. Finger guards, drinking fluids for heat stress relief, and removing splinters or foreign material from other parts of the body through use of tweezers, irrigation, swabs, or other simple means are also considered first aid.

Last, use of massage is considered first aid while physical therapy or chiropractic treatment are not.  In all cases, review the instructions provided to your injured employee by the medical provider to assist in making the determination of whether medical treatment was received.

Another source of stress is determining if the injury your employee has received falls under the 24-hour reporting requirements because it is defined as an amputation.  Here again, the official diagnosis from a licensed healthcare provider is what will be needed to make that determination.  Since there is a 24-hour window from the time that the injury is reported, use that window to gather as much information as possible.

An amputation is defined as a traumatic loss of a limb or other external body part.  This includes appendages severed, cut off, amputated completely or partially, fingertip amputations with or without the loss of bone, medical amputations resulting from irreparable damage, and amputations of body parts that were successfully re-attached.  

The above definition does not include avulsions; which is a body structure forcibly detached from its normal point of insertion, enucleations; which is the removal of an eye that leaves the eye muscles and remaining orbital contents intact, degloving injuries; which is a type of avulsion in which an extensive section of skin is torn off the underlying tissue severing its blood supply, scalping, severed ears, or chipped and/or broken teeth. 

If the 24-hour reporting deadline is approaching and it is still unclear if the injury is classified as an amputation, report the facts that are available to OSHA and advise that the company will follow up once additional information is received from the medical provider.  Keep in mind, medical providers are often unaware that OSHA has this reporting requirement and may be hesitant to provide a diagnosis to an employer representative, forcing the employer to wait until the information becomes available from the worker’s compensation carrier.  

The last item that tends to cause confusion surrounds the reporting of an in-patient hospitalization.  The key component that makes a hospitalization reportable is that the employee has been admitted for care or treatment.  If the employee is admitted for observation or diagnostic testing, then the instance is not reportable.  Recordkeeping FAQ Search | Occupational Safety and Health Administration (osha.gov)  For example, an employee suffers a concussion when he inadvertently steps on the crane remote control that he left on the floor, bringing the load down rapidly onto his hard hat. He is diagnosed with a concussion at the emergency room but does not have anyone at home to perform the necessary concussion monitoring protocol and is admitted for observation. This case is not reportable as an in-patient hospitalization.

Recordkeeping can be confusing, particularly when determining work-relatedness and recordability.  The FAQ below contains multiple pages of questions and examples from employers asking about specific instances that have occurred in the workplace.  Reference these examples for information on OSHA’s recommended practices to record (or not record) specific injuries.

Recordkeeping FAQ Search | Occupational Safety and Health Administration (osha.gov)

Tags: First Aid, OSHA 300, Recordkeeping, Reporting