How to Determine if an Injury is OSHA-Recordable

Author: William Principe
If an employee walks to a cafeteria carrying his/her lunch box and he/she slips and get injured, would the injury be considered as recordable under 29 CFR 1904? In order to identify whether the injury is an OSHA recordable event, first find out whether or not the injury needed medical treatment. If administered medical treatment, then the injury could be recordable.
1. Medical Treatments
1904.7(b)(5)(ii) is an exclusive list of the 14 treatments that OSHA considers to be “first aid.” The status of the person providing the treatment does not determine whether “medical treatment” has been provided.Diagnostic procedures such as X-rays and MRIs are not “medical treatment.” But treatments involving antibiotics to prevent infection are considered as medical treatments.
2. Treatments that Get Missed By Record-Keepers
Using non-prescription medication at non-prescription strength is first aid, but use of non-prescription medication at prescription strength = medical treatment such as Ibuprofen at > 467 mg,Diphenhydramine at greater than 50 mg,Naproxen Sodium at greater than 220 mg, and Ketoprofen at greater than 25 mg.
3. Administering oxygen
If oxygen is administrated as a purely precautionary measure to an employee who does not exhibit any symptoms of an injury or illness, the case is not recordable. If the employee exposed to a substance exhibits symptoms of an injury or illness, the administration of oxygen makes the case recordable.
4. Wrist support
Any non-rigid means of support, e.g., elastic bandages, wraps, non-rigid back belts, etc. (Devices with rigid stays or systems designed to immobilize body parts are medical treatment.)
5. Exercises
Using massages like physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes. Exercises performed at work or at home are medical treatment.
6. Restricted Work Activity
RWA occurs whenemployer or PLHCP recommends that employee not perform one or more routine functions of the job, or not work the full workday that employee would otherwise have been scheduled to work.
7. Resolved
Resolved means all signs and symptoms disappear, no more medical treatment required, no restricted work activity or day(s) away from work, passage of time since symptoms last occurred. If the symptoms disappear for a day and reappear the next day, OSHA would consider that “strong evidence” that the employee was not completely healed.

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