Recordability Sample Scenarios
Since each illness and injury situation is unique to each establishment, determining the recordablility of each case can be a challenge. Below are several sample scenarios that may help you make the determination on whether your particular case is recordable under the OSHA injury and illness recordkeeping regulations.
"We hire several temporary workers from a staffing agency for summer work. Although the staffing agency pays the workers, they report to us, and we supervise them on a daily basis. One morning one of the temporary workers fell from a ladder and broke her ankle. Do we need to record this injury on our OSHA 300 Log?"
Answer: Yes. You must record the injury, even though the worker is not on your payroll. If you supervise a worker on a daily basis, then you must record any injuries and illness on your OSHA 300 Log.
"One of my employees hurt her finger and went to the doctor. The doctor gave her a finger guard, and sent her back to work with no restrictions. He did not tell her to take any time off. Do I need to record this injury?"
Citation: 1904.7(b)(4)(iii), 1904.7(b)(5)(ii)(L)
Answer: No. You do not have to record restricted work that you or a physician imposes only for the day on which the injury occurred. The finger guard, although rigid, is considered a first aid treatment.
"Sam twisted his back while lifting a shipment of boxes. He just put some ice on it for a couple of hours and went back to work. Is this recordable?
Answer: Maybe. Putting ice on the injury is considered first aid; therefore the injury would not be recordable. However, if the employee needs to limit the amount of lifting he does, and lifting is a routine function of the employee’s job, you may need to record the injury as restricted work.
"What about an employee who had to have a fingernail drilled to relieve pressure? She returned to work the same day with no restrictions. Is this recordable?"
Answer: No. Drilling a fingernail or toenail to relieve pressure is considered first aid.
"We had a worker go to the doctor for a cut finger. The doctor prescribed a pain medication to be taken as needed. If the worker never filled the prescription, do we still need to record the injury?"
Answer: Yes. The prescription makes the injury recordable, even if the employee never filled it.
"What if the doctor only tells the employee to take an over-the-counter pain medication at a prescription strength?"
Answer: Same answer. OSHA says that a recommendation by a physician to use a non-prescription medication at prescription strength is considered medical treatment.
"Our maintenance director was stung by a bee while inspecting the grounds yesterday. He’s allergic to bee stings and carries an Epipen with him. He gave himself an Epipen shot, went to the emergency room, and was able to return to work the next day. Do we need to record this?"
Answer: Yes. Even though an Epipen is self-administered, it’s still considered “medical treatment” for recordkeeping purposes. It’s both a prescription medication, and not included on OSHA’s list of first aid treatments.
"Betty's hand slipped while working with some machinery and she chipped a tooth. Otherwise, she’s fine. Is this recordable?"
Answer: Yes. Chipped or broken teeth are always recordable. OSHA considers these cases to be “significant injuries,” even if they don’t meet any of the other recordable criteria such as days away from work or medical treatment beyond first aid.
"Don was on medical leave for two weeks before he quit to move to another state. Do we need to keep counting his days away on our OSHA 300 Log?"
Answer: You can stop counting the days away if the employee leaves the company for personal reasons. However, if the employee leaves the company for a reason related to the injury or illness, then you must estimate the number of days away the employee would have had.
"How do we count the number of days away when one of our workers reached the 180 day cap for restricted work and then was allowed to stay home to recuperate?"
Citation: 1904.7(b)(3) (vii)
Answer: OSHA wants employers to check the box associated with the most severe outcome of the injury or illness. In your case, you would remove the check from the "Job transfer or restriction" box and move it to the "Days away from work" box. You would have to enter at least one day in the "Days away from work" column.
"Hettie was running late for work last week and she ran her pickup truck into the back of another employee’s car. The other employee was fine, but Hettie suffered a laceration to her forehead that required stitches. Do we need to record this?"
Answer: No. You do not need to record motor vehicle accidents that occur on company parking lots while employees are commuting to or from work. However, OSHA says that some injuries and illnesses that occur in company parking lots are work-related. Examples include an employee who conducts work in the parking lot, or an employee who slips and falls on ice that the employer allowed to build up.
"Riley fainted while standing at a workbench and broke a rib. It turns out he forgot to take his diabetes medication that morning. Do we need to record the broken rib injury?"
Answer: No. OSHA allows you to exclude cases where a loss of consciousness, and resulting injuries, are due solely to a personal health condition such as diabetes, epilepsy, or narcolepsy.