Frequently asked questions about:
1. How to get started
3. Is this incident recordable?
4. When to report injuries to OSHA
Is This Recordable?
OSHA requires certain employers to complete the OSHA packet each year and have the 300A Summary form posted by February 1st. Filling out the OSHA 300 packet and also trying to determine what is, or is not considered a recordable injury can be confusing at times. For this reason, Lancaster Safety Consulting, Inc. (LSCI) hosts an annual Recordkeeping webinar which is available for free! Register for one of our webinars today by clicking here.
Q: What is recordable under OSHA’s recordkeeping requirements?
A: OSHA’s definition of work-related injuries, illnesses, and fatalities are those in which an event or exposure in the work environment either caused or contributed to the condition. In addition, if an event or exposure in the work environment significantly aggravated a pre-existing injury or illness.
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: 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.
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: Yes, the doctor's medical recommendation of physical therapy, which is considered to be medical treatment, which deems this incident as recordable.
Q: An employee cut his finger and received stitches. Does this have to be recorded on our OSHA 300 log? Refer to 1904.7(b)(5)(ii)(D).
A: Yes, any injury that required medical attention beyond first aid must be recorded on the log.
Q: We had an employee cut the tip of his finger off and went to the hospital. The employee was given a prescription. Is this a recordable incident?
A: Yes, it would be considered a recordable since the employee was prescribed medication and the finger was partially amputated. The amputation would also need to be reported to OSHA within 24 hours.
Q: An employee got something in their eye. They didn't feel the need for any treatment, but we sent them to the emergency room. The emergency room flushed their eye and released the employee without any other medical attention or follow-up. How do we record this incident?
A: Due to the fact that the medical professional only flushed the eye with solution to cleanse the employee's eye, did not forceps to remove the irritant, or recommend any time off/restricted work then this incident would not be recordable.
Q: If an employee is sent by a doctor to a physical therapist for several visits to receive massages is that a recordable case?
A: You must consult the physical therapist and determine if the treatment would be considered massage therapy or physical therapy. If the treatment is considered massage therapy, then the injury would not be recordable. If the therapist considers the treatment to be physical therapy, then it would be considered recordable.
Q: Is this case recordable? An employee was struck by a vehicle while walking to his car after a day of work. He went to the emergency room and received X-rays and was recommended for light duty.
A: Yes, this case would be recordable because the employee was injured in the company parking lot which is considered to be the work environment.
Q: If an employee is injured in a car accident on the way to or from a job site and the accident does not occur in the parking lot or access road - is the accident is recordable?
A: If the employee was on their normal commute to work in a motor vehicle accident, then the case would not be recordable. OSHA considers the employee's commute from home to work to end, once he or she arrives at the work environment (i.e. parking lot, office, jobsite, etc.) or when he or she starts traveling "in the interest of the employer."
Q: If a company gets bought out midway through the year to new ownership, how does management fill out the recordkeeping forms?
A: As the employer, you are responsible for filling out the OSHA recordkeeping forms only for the period of the year during which you owned the establishment. For example, if you own a company until June, you would fill out the average number of employees, hours worked, injuries, etc. from January to June. The new owner would then be required to fill out the OSHA forms for July to August.
Q: An employee fell on the snow/ice and hurt his leg and the doctor prescribed several days off of work. Is this recordable?
A: Yes, this incident is recordable since the injury occurred while the employee was at work and it resulted in days away from work.
Q: Do we need to include temporary employees on our OSHA logs?
A: Yes, if the employees are under direct supervision of your company.
Q: When counting days away from work or light duty, do I count workdays or calendar days?
A: You want to count all calendar days that the employee is off, up to 180.
Q: An employee hurt their back and was given a prescription, but they did not miss any work. Is this recordable?
A: Yes, it is recordable because the employee was prescribed medicine.
Q: How do I handle a case when a physician recommended that the worker return to work, but the employee stays at home anyway?
A: In this situation, you end the count of 'days away from work' on the date the physician recommended that the employee return to work.
Q: How do you count the lost work/restricted days on the OSHA 300 log?
A: You'll need to count all the days away from work starting the day after the employee was injured (even if it’s a weekend, or an employee is not scheduled). When the employee returns for restricted/light duty, count those days until they returned to full duty.
Q: One of our employees slipped on ice and hurt their neck. They were off for more than a year. Is there a limit to days that need to be recorded?
A: Yes, you may "cap" the total days away at 180 calendar days.
Q: An employee got a piece of metal in his eye, and he was taken to the emergency room to remove it and was given a one-time use nonprescription eye drops. He later returned to work the same day. Is this a recordable injury?
A: No, this would not be considered a recordable incident because the foreign object in the eye was removed by eye drops, not forceps, and because there is no loss of workday or restriction/job transfer.
Q: An employee was struck by a piece of equipment in the face and went to the ER, they were physically observed by a physician, and it was determined there was no other injuries besides bruising on their face, they did not miss any work; is this recordable?
A: If there was no other treatment besides an observation and basic first aid, then no it is not recordable.
Q: An employee had recently fractured a finger, received stitches in another, and missed days away from work; is this recordable?
A: Yes, their treatment would be considered medical treatment and they missed days from work.
What to Report to OSHA
Q: What accidents need to be reported to OSHA?
A: Report work-related fatalities right away - no longer than 8 hours. Work-related amputations, losses of an eye, or impatient hospitalization of a worker must be reported within 24 hours.
Q: Do I need to report my OSHA recordkeeping forms to OSHA?
A: You'll need to summit the injury and illness data by March 2nd if you have:
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- 20-249 employees classified with historically high rates of occupational injury & illness (refer to 300A Table)
- 100+ employees in designated industries (refer to Appendix D)
- 250 or more employees that are not exempt (refer to Appendix A)
- Still unsure? Use OSHA's Injury Tracking Application | Occupational Safety and Health Administration