OSHA Recordkeeping: Understanding Recordable vs. Non-recordable cases
By: Laura Palmer, Pinnacol Assurance Network Educator
OSHA regulates work-related injury and illness recordkeeping. Along with other criteria, injuries and illnesses that require medical treatment beyond first aid must be recorded by many employers.
There are also special recording criteria for work-related cases such as those involving needle sticks, sharps injuries, hearing loss and tuberculosis.
Recordable cases may impact the company’s ability to bid on and secure new projects, particularly in the construction industry.
Medical providers who treat injured workers may be able to reduce the number of recordable incidents for employers by becoming knowledgeable of the OSHA categories of recordable (medical treatment) and non-recordable (first aid) incidents.
According to OSHA, first aid treatment is very broad and may seem to include procedures that are beyond first aid.
As an example, for the treatment of cuts, lacerations, punctures, and abrasions, OSHA does not require recording for wound coverings such as bandages, BandAidsTM, gauze pads, Steri-StripsTM or butterfly bandages. However, if the treatment requires sutures, staples or surgical glue, the incident would be recordable.
Prescription medication, whether given once or over a longer time period, and regardless of whether it is taken by the injured worker, requires the employer to record the injury on its OSHA log.
Non-prescription medication at nonprescription strength, in any form, does not require recording by the employer. However, for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength, is considered medical treatment for recordkeeping purposes.
Immunizations such as rabies and hepatitis B vaccines are recordable, whereas tetanus immunization is not. X-rays for diagnostic purposes are considered first aid and not recordable.
Physical therapy and chiropractic treatment are recordable but hot and cold therapies and massages are not. Immobilizing devices with rigid stays are recordable but elastic bandages, wraps and non-rigid back belts are not recordable.
Under the first aid description for OSHA, removal of foreign bodies from the eye using only irrigation or a cotton swab is not recordable. Neither is removing splinters or foreign bodies from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means.
The summary from J.J. Keller is a quick reference available to assist employers with work-related injury and illness recordkeeping requirements.