12 Common OSHA Recordkeeping Mistakes
OSHA recordkeeping can be complex, and even experienced EHS professionals can make mistakes. Below are 12 common errors and how to avoid them.
1 Failing to Record a "Significant" Injury or 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 include:
- Cancer
- Chronic irreversible diseases (e.g. asbestosis, silicosis)
- Punctured eardrum
- Fractured or cracked bone or tooth
2 Not Recording "Fainting" Incidents
In accordance with 29 CFR 1904.7(b)(6), instances of fainting are subject to recording when they are determined to have a direct connection to work-related activities. This includes scenarios where fainting occurs due to exposure to gory content in a training video or during work-related blood draws.
3 Not Recording Certain Prescriptions for Over-The-Counter Medications
If a physician or other licensed healthcare professional (PLHCP) recommends that an employee take an Over-the-Counter (OTC) medication in excess of the OTC dosage, the injury or illness is recordable.
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 or 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
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.
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 is not relevant who provides the medical treatment (i.e. the case must be recorded even if the employee reduces the dislocation themselves).
8 Not Recording Cases Involving Occupational Hearing Loss
Work-related hearing loss cases must be recorded where:
- The employee has experienced a Standard Threshold Shift (STS), and
- The employee's hearing level is 25 decibels (dB) or more above audiometric zero (averaged at 2000, 3000, and 4000 hertz) in the same ear(s) as the STS
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.
Several criteria must be met to ensure the medical professionals 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
- 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
Per 29 CFR 1904.31, employers must record injuries and illnesses that occur to employees not on their payroll if they supervise them on a day-to-day basis. In other words, companies must only include subcontractor injuries and illnesses if they direct (i.e. supervise) 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
- 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 PLHCP 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 need to be recorded.
