#1 - Failing to Record a "Significant" Injury and Illness.
Per 29 CFR 1904.7(b)(7), a "significant" work-related injury or illness is recordable even if it does not result in death, days away from work, restricted work, job transfer, medical treatment beyond first aid, or loss of consciousness. Examples of "significant" injuries and illnesses may include:
- Chronic irreversible diseases (e.g. asbestosis, silicosis, etc.)
- Punctured eardrum
- Fractured or cracked bone or tooth
#2 - Not Recording "Fainting" Incidents.
"Fainting" is a loss of consciousness and thus must be recorded in accordance with 29 CFR 1904.7(b)(6) if it is determined to be work related. "Fainting" from watching a gory training video or during a work-required blood draw are examples that would need to be recorded.
To avoid this mistake, train supervisors on the need to be notified of such incidents and carefully evaluate their work-relatedness when they do occur.
#3 - Not Recording Certain Prescriptions for Over-The-Counter Medications First Aid.
If a physician or other licensed healthcare professional (PHLCP) recommends that an employee take an Over-the-Counter (OTC) medication in excess of the OTC dosage, the injury or illness is recordable.
To avoid this mistake, if paperwork received from the PHLCP recommends a specific dosage of an over-the-counter medication, check with OSHA or the FDA to verify whether that dosage is in excess of the OTC dosage. Note that this is fairly common for medications such as acetaminophen, ibuprofen, and naproxen.
#4 - Counting Any Type of IV As Recordable.
An IV put in place solely as a delivery system for medication is not considered "medical treatment".
However, if medication is actually delivered, administration of that medication would be "medical treatment" and the case must be recorded.
Use of an IV is also considered "medical treatment" if it is provided to treat an employee's condition such as dehydration or heat stress.
#5 - Not Recording Cases Involving Physical Therapy and Therapeutic Exercise.
Both Physical Therapy and Therapeutic Exercise are considered "medical treatment" if they are prescribed/performed as a result of a work-related injury or illness. This includes:
- Written home exercise programs (including sets, reps, and resistance)
- An athletic trainer utilizing stretching to relieve symptoms
Note that the duration or number of treatments does not matter.
#6 - Recording Any Case Involving the Administration of Oxygen.
If oxygen is administered as a purely precautionary measure to an employee who does not exhibit any symptoms of an injury or illness, the case is not recordable. However, if an employee is exposed to a substance and exhibits symptoms of an injury or illness, the administration of oxygen makes the case recordable.
To avoid this mistake, clearly understand why the oxygen was delivered prior to recording the case.
#7 - Not Recording Dislocations.
Reduction of a dislocated joint is not listed on OSHA's first aid list (see 29 CFR 1904.7(b)(5)(ii)) and thus is considered "medical treatment". It does not matter who provides the medical treatment (i.e. the case must be recorded even if the employee reduces the dislocation themself).
#8 - Not Recording Cases Involving Occupational Hearing Loss.
Work-related hearing loss cases must be recorded where:
- Employee has experienced a Standard Threshold Shift (STS), and
- Employee's hearing level is 25 decibels (dB) or more above audiometric zero (averaged at 2000, 3000, and 4000 hertz (Hz)) in the same ear(s) as the STS
An STS is defined in OSHA's noise standard as a change in hearing threshold, relative to the baseline audiogram, of an average of 10 dB or more at 2000, 3000, and 4000 Hz in one or both ears. (see 29 CFR 1910.95(g)(10)(i))
#9 - Evaluation of Differing Medical Opinions.
If different medical professionals see the "exact same condition" but provide differing medical opinions, you must follow the opinion that is most authoritative. However, once medical treatment is provided, if days away occur or restricted work occurs, the case is recordable regardless of a second opinion.
For prescriptions, it is important to note that medical treatment is provided when the prescription is written.
Several criteria must be met to ensure the medical professionals involved are seeing the "exact same condition":
- Examination of the patient must be in person;
- The examinations must be contemporaneous;
- The employee was not subject to additional exposures between the examinations; and
- No medical treatment, restricted work activity, or days away from work occurred between the examinations.
If any one of these criteria is not met, it is likely the healthcare professionals are not seeing the same condition.
#10 - Including Subcontracted Employee Injuries On Your Recordkeeping Forms.
29 CFR 1904.31 states employers must record injuries and illnesses that occur to employees not on its payroll if it supervises them on a day-to-day basis. In other words, companies must only include subcontractor injuries and illnesses if they direct (e.g. supervise) that employee's work activities.
To avoid this mistake, understand the relationship between your company and subcontractors and only record injuries or illnesses that if your company directs (e.g. supervises) that employee's work activities.
#11 - Recording Cases Due to Diagnostic Procedures.
"Medical Treatment" does not include diagnostic procedures such as:
- Visits to a PLHCP solely for observation or counseling; and
- Diagnostic procedures such as x-rays and blood tests.
As such, cases that only involve these types of diagnostic activities do not need to be recorded.
#12 - Not Recording Cases Where a PLHCP Limits An Employee From Performing a Full Day's Work.
A PHCLP recommendation that prevents an employee from working the entire time they were scheduled to work (such as a recommendation for rest every half hour; use ice for 15 minutes every hour; elevate your leg as much as possible; or work as tolerated) would make a case recordable.
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