OSHA 300 Log – Recordable or Just First Aid?
Many times, an injury occurs, and companies are not prepared as to how to handle and track this injury, especially when it comes to whether it is recordable or not per OSHA. Not all injuries need to be recorded on the OSHA 300 Log.
OSHA 29 CFR 1904.4 requires covered employers to report work-related injuries and illnesses if they involve medical treatment beyond first aid. If you only administer first aid, you do not have to record the injury or illness. Knowing the difference will help you improve the accuracy of your OSHA Logs and reduce over-reporting. Employers who are over-reporting their injuries may unknowingly push their incident rate over the industry standard, leading to an increased risk of OSHA inspections.
OSHA defines medical treatment as the management and care of a patient to combat a disease or disorder. OSHA’s definition of medical treatment does not include visits to a physician or other licensed health care professional solely for observation, counseling, diagnostic procedures or first aid. Medical treatment beyond first aid is a criterion that determines if a work-related injury or illness is OSHA recordable. Any work-related incident where the involved parties received medical treatment other than first aid is considered OSHA recordable.
According to OSHA, first aid refers to medical attention that is usually administered immediately after the injury occurs and at the location where it occurred. It often consists of a one-time, short-term treatment and requires little technology or training to administer. A general rule of thumb is anything that does not fall under OSHA’s definitions of first aid should be considered medical treatment. Under 29 CFR 1904.7(b)(5)(ii) first aid only includes the following types of care:
Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment); Cleaning, flushing or soaking wounds on the surface of the skin
Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
Using hot or cold therapy;
Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.). Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
Using eye patches;
Removing foreign bodies from the eye using only irrigation or a cotton swab;
Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
Using finger guards;
Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
Drinking fluids for relief of heat stress.
Keep in mind, however, that medical treatment beyond first aid is not the only criterion that determines if an injury is OSHA recordable. Other factors include days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or death. You must also consider a case to meet the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
OSHA’s Electronic Submission Policy requires companies in certain industries with more than 20 employees to submit information from their 300A Summary via the OSHA ITA application. OSHA uses the summary injury and illness data to target high-risk establishments for certain comprehensive inspections (such as their National Emphasis Programs). If your incident rate is above that of your industry group average, you will likely be inspected by OSHA. Which is why it is important to review your OSHA 300 Log entries thoroughly using the OSHA recordkeeping criteria to make sure you have not over-reported injuries.
For a tutorial on how to complete the OSHA recordkeeping forms, visit http://www.osha.gov/recordkeeping/tutorial.html.
For detailed guidance for OSHA’s Injury and Illness Recordkeeping Rule, visit https://www.osha.gov/recordkeeping/entry-faq.
Please do not hesitate to contact ACS with any questions that you might have, anytime when an accident or injury occurs. We can help you review your OSHA 300 Log to determine whether there are unnecessarily recorded injuries raising your incident rates unnecessarily.