Recordable Injuries

Q: Do we need to include recordable injuries of our subcontractors in the field that aren’t on our payroll, but are paid through purchase orders?

A:You must record the recordable injuries and illnesses that occur to employees who are not on your payroll if you supervise these employees on a day-to-day basis. If the subcontractor’s employee is under the day-to-day supervision of the subcontractor, the subcontractor is responsible for recording the injury or illness. If you supervise the subcontractor employee’s work on a day-to-day basis, you must record the injury or illness.  It would be recommended to have a contract in place with all subcontractors to distinguish who is liable for safety and the overall supervision of the workers. You want to eliminate the possibility of having the injury recorded on two separate companies’ OSHA 300 logs.

Q: If an employee quits during “light duty” do I have to continue to count the days that he works until released to full duty?

A: If the employee leaves your company for some reason unrelated to the injury or illness, such as…

Q: A death within 30 days of the incident must be reported within 8 hours. What if an amputation occurs long after the incident, but due to damage at work, is there a time limit when the amputation is considered as related and reportable?

A: For an amputation, you must only report the event to OSHA if it occurs within 24 hours of the work-related incident. However, it must be recorded on your OSHA injury and illness records. You can refer to 1904.39(b)(6) for more information.

Q: What is the process to report a minor injury to OSHA?

A: You only need to report an injury to OSHA in the following circumstances:
• A work-related fatality – must be reported within 8 hours
• A work-related in-patient hospitalization – must be reported within 24 hours
• A work-related amputation – must be reported within 24 hours
• A work-related loss of an eye – must be reported within 24 hours

If any of the above have occurred, you can call 1-800-321-6742 and report the injury.

Q: An employee cut their thumb on Monday and reported it to a supervisor. The cut didn’t look to severe so it was wrapped with a bandage. On Tuesday, the employees went to Med Express and they put in 10 stitches. Is this recordable incident?

A: Yes, because the cut required stitches, which are considered medical treatment beyond first aid measures, then it would be considered a recordable incident.

Refer to 1904.7(b)(5)(ii) for more information on what OSHA outlines as ‘first aid’ treatment.

Q: An employee was diagnosed with carpal tunnel in 2014 and was approved for surgery at this time. However, he postponed the surgery until September in 2015 due to a sickness in his family. Do we record the injury on both the 2014 OSHA 300 log and the 2015 OSHA 300 log?

A: Regarding the employee’s carpal tunnel injury in 2014 and medical treatment in 2015, it is necessary to record the injury when it originally occurred in 2014. The details of the injury, days away/on restriction should be logged only on the 2014 OSHA 300 log as they pertain to the original injury. Any updates to the employee’s treatment should also be reflected on the 2014 OSHA 300 log. Make sure you are retaining all OSHA 300 logs for 5 years following the year that they cover and update them during that period as needed.

Refer to 1904.7(b)(3)(ix) and 1904.33(b)(1).

Q: How do you find the recordable incident rate for your company’s industry average?

A: You can find that information and anything else pertaining to incident rates, recordable incidents, days away from work, etc. on the Bureau of Labor Statistics’ website…

Q: We had an employee twist their knee in the shop. They went to the hospital for a medical evaluation and received a prescription for pain medication. Does that count as a recordable injury?

A: Yes, since the employee was given a prescription, you would need to record the injury.

Refer to 1904.7(b)(5)(ii)(A).

Q: How soon after an injury do I need to put the injury on the OSHA log? What type of injuries do I need to report on OSHA log and what not? Are there any injuries that I need to call into OSHA to inform them of the injury ?

A: OSHA classifies the following types of injuries below as a “recordable” injury:
-Fatality (You also have to report it to OSHA within 8 hours.)
-Injury that caused days away from work
-Injury that caused restricted work or had the employee transfer to another job
-Medical treatment beyond first aid. 1904.7(b)(5)(i)(C)
-Loss of consciousness

All fatalities must be reported to OSHA within 8 hours of the incident.
All work-related inpatient hospitalizations, amputations, and loss of an eye must be reported within 24 hours of the incident.
All OSHA-recordable injuries/illnesses must be entered on the log within 7 days of the injury or illness.

Q: We have an employee who went to the doctor for a sore knee after lifting heavy items at work. An x-ray was taken and showed no injury so they set up the employee for a couple of weeks of physical therapy. Does the physical therapy make this an OSHA recordable incident?  He has no work restrictions.

A: The doctor’s medical recommendation of physical therapy, which is considered to be medical treatment, deems this incident as recordable.

Refer to 1904.7(b)(5)(ii)(M).

Q: If an employee stepped on a nail and had to miss the rest of the day for medical evaluation, is it considered a day away from work and therefore recordable?

A: No, you begin counting the days away from work on the day after the injury occurred or the illness began.

Refer to 1904.7(b)(3) and 1904.7(b)(3)(i).

Q: Do I record an injury that required a tetanus shot?

A: No, administering tetanus immunizations is considered first aid.

Refer to 1904.7(b)(5)(ii)(B).

Q: Do we report an accident that may or may not have led to an amputation?

A: For an amputation, you must only report the event to OSHA if it occurs within 24 hours of the work-related incident. However, it must be recorded on your OSHA injury and illness records. You can refer to 1904.39(b)(6) for more information.

Q: We have an employee who was injured in late 2014 and was on restriction days beginning in 2014 but also overlapping into 2015. Do all of the restricted duty days get recorded in the year that the injury occurred even if they occurred in the following year. If not, how do we record a 2014 injury along with its 2015 restricted days on a 2015 log?

A: According to OSHA, you only record the injury or illness once. You must enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap.

Refer to 1904.(b)(3)(ix).

Q: How do you calculate the following:

1. Incident Rate of Recordable Cases
2. Incident Rate of Lost Workday Cases

A: 1. The OSHA Recordable Incident Rate (or Incident Rate) is calculated by…