As an employer, one of the many things you must tackle is ensuring you understand OSHA’s many regulations. One of the more confusing parts (there are many) is the injury and illness reporting requirements.

In this post, we will walk you through how to determine if an injury is ‘recordable,’ how to maintain an OSHA 300 log and the annual posting requirements. Also, we will cover the requirements for reporting severe injuries to OSHA and how to ensure the best possible outcome by completing a comprehensive internal investigation.

Understanding ‘Recordable’ Injuries and Illnesses

Determining if an injury or illness is ‘recordable’ is the first step in OSHA reporting. An incident is recordable if:

• The worker requires more than basic first aid. (The next section covers what OSHA considers first aid.)

• The injury or illness leads to missed work, a job transfer, or limitations (light or restricted duty).

• The worker contracts a significant illness due to their job.

This ‘recordable’ status applies irrespective of whether the incident was the employer’s fault.

Making Sense of OSHA’s Medical Treatment and First Aid Definitions

When it comes to OSHA rules, it’s vital to understand the difference between ‘medical treatment’ and ‘first aid.’ These terms are critical when tracking injuries. OSHA’s definition of first aid can be found in the Standard for Recording and Reporting Occupational Injuries and Illnesses, 29 CFR Part 1904.7(b)(5)(ii). It outlines activities considered as first aid for the purposes of OSHA recordkeeping. As always, we recommend you consult the standard for your situation.

Medical Treatment:

Medical treatment means anything that is not classified as first aid under the OSHA standard, but here are a few items that often need clarification:

1. Simply going to a doctor or a health care professional for advice or to be watched isn’t medical treatment.

2. Having tests done are considered diagnostics, not medical treatment (for example, X-rays or blood tests). This also includes using prescription medication for testing, like using eye drops to make pupils bigger.

3. Anything not listed as ‘first aid’ in the OSHA standard is medical treatment- we’ll talk about what that means next.

First Aid:

First aid includes:

1. Using a non-prescription medication at non-prescription strength, i.e., the same strength you’d find at a drugstore. But, if a health care professional tells you to use over-the-counter medication at prescription strength, OSHA would technically count that as medical treatment.

2. Giving tetanus shots. Shots for other things, like Hepatitis B or rabies, count as medical treatment.

3. Cleaning or soaking minor skin wounds.

4. Using items such as bandages, Band-Aids™, or gauze pads. If you need to use something more serious to close a wound, like stitches, that’s considered medical treatment.

5. Applying hot or cold packs.

6. Using flexible supports like elastic bandages or wraps. If you use a device that can’t bend to support a part of the body (considered a rigid support), that’s medical treatment.

7. Using temporary supports, like slings or backboards, to move someone.

8. Drilling a fingernail or toenail to relieve pressure or drain fluid from a blister.

9. Using an eye patch.

10. Removing something from the eye using only water or a cotton swab.

11. Taking splinters or other things out of the skin (other than the eye) using water, tweezers, cotton swabs, or other simple methods.

12. Using finger guards.

13. Giving massages. If you need physical therapy or chiropractic treatment, that counts as medical treatment and must be recorded on your OSHA300 log.

14. Drinking fluids to help with heat stress.

These are the only things OSHA counts as first aid. Remember, it’s not about who provides the treatment; even if a doctor provides first aid, it’s still first aid. And if someone that’s not a doctor provides medical treatment, it’s still medical treatment. It all depends on what kind of treatment is being given.

Ensuring a clear understanding of what constitutes first aid is vital to keeping your OSHA 300 log accurate.

Keeping an OSHA 300 Log

The OSHA 300 Log details work-related injuries and illnesses. Here is a quick link to the pdf and Excel versions. Here’s how to maintain the log:

1. Identify a case: Use the above guidelines to see if an injury or illness is ‘recordable.’

2. Describe the case: Record the details: Include the date, location, nature of the injury or illness, and the employee’s name (unless privacy rules apply).

3. Classify the case: Specify whether it’s an injury or illness. Also, indicate if it involves any days away from work, a job transfer, or restrictions.

4. Track the case: Document how many days (calendar days) the employee was away from work or had job restrictions.

Annual Posting Requirements

Employers must post a summary of the previous year’s injuries and illnesses, known as the OSHA 300A form. This is a requirement every year from February 1 to April 30. Display this summary in common areas where notices to employees are typically posted. It’s also necessary to keep your log for five years. Regardless of the regulation, you should maintain these logs for internal trend analysis. I recommend keeping them for at least ten years.

Reporting Severe Injuries to OSHA

Certain severe incidents must be reported directly to OSHA and promptly. These include:

• Any work-related fatality.

• Any work-related injury leading to in-patient hospitalization.

• Any work-related incident causing an amputation or loss of an eye.

In case of a work-related fatality, you must report the incident to OSHA within 8 hours. The reporting deadline for in-patient hospitalization, amputation, or loss of an eye is 24 hours. You can report these incidents to OSHA by calling the nearest OSHA office. You can also call the OSHA 24-hour hotline at 1-800-321-OSHA (1-800-321-6742) or report online at www.osha.gov.

Remember to include details like the establishment’s name, incident location, time, type of event, the number and names of affected employees, your contact person, and a brief description of the incident. You can find the online form here: https://www.osha.gov/ords/ser/serform.html.

Prompt Incident Investigation: Why a Timely Investigation is Important

If a serious incident occurs, OSHA may decide to investigate the cause and whether any safety regulations were violated.

However, if an employer can conduct a thorough, prompt internal investigation immediately following the incident, document the findings, and take appropriate corrective actions, OSHA may accept this investigation report instead of conducting its own inspection.

Such an approach has several benefits:

• Efficiency: An internal investigation report can save everyone time, allowing quicker resolution.

• Less Disruption: A well-conducted internal investigation can reduce the potential impact on productivity.

• Regulatory Relationship: Timely and effective internal investigations demonstrate your commitment to safety. This action also shows that you have an appropriate response system for dealing with incidents. Lastly, this response can foster a positive relationship with the agency.

Conducting a timely internal investigation is vital. Don’t waste any time. Immediately investigating an incident offers several advantages.

1. Accurate and Comprehensive Information: The sooner an investigation begins, the more accurate and complete the information collected. Witnesses’ memories are fresh, and the conditions surrounding the event are less likely to have changed, providing a clear picture of the incident’s circumstances.

2. Swift Identification of Hazards: A timely investigation allows for quickly identifying any safety hazards that contributed to the incident, enabling immediate action to prevent further occurrences.

3. Preserve Evidence: Prompt investigation helps to secure and preserve physical evidence before it can be moved, altered, or degraded.

By promptly investigating an incident, you send a clear message to your employees, OSHA, and your insurance carrier that safety is your top priority.

We have built a free app if you still need help determining OSHA recordability.

Disclaimer This app is for informational purposes only. It is ultimately your responsibility to ensure you have kept an accurate OSHA 300 log.