OSHA doesn’t require you to record injuries that only require first aid. But it isn’t always easy to determine when an incident is recordable and when it isn’t.
At most workplaces, injuries requiring only first aid are commonplace. But sometimes there’s a fine line between types of cases OSHA considers "other recordable" and those that are classified as simply first aid and not recordable.
Other Recordable
A case should be recorded in the OSHA 300 log if it involves treatment beyond first aid or a diagnosis of significant injury or illness. If the employee did not have days away from work (Column H) or job transfer or restriction (Column I), the case is recorded in Column J: Other Recordable Cases. You must also record the appropriate category under Column M: Injury and Illness Types.
Examples of these cases include:
- Medical treatment that does not fall under first aid, such as treatment involving prescriptions for medications, rigid devices for immobilizing body parts, and wound-closing devices such as surgical glue, sutures, or staples.
- Significant diagnosed injury or illness, which includes any serious or significant work-related disorder that is diagnosed by a physician or other licensed healthcare professional or identified by a positive medical test (for example, cases of cancer, chronic irreversible disease, a fractured or cracked bone or tooth, or a punctured eardrum).
- Needlestick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious materials.
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- Medical removal of an employee for medical surveillance as required by an OSHA standard.
- Loss of consciousness from a work-related injury or illness (however, loss of consciousness due solely to a personal health condition such as diabetes or epilepsy is not recordable).
Not Recordable
If a case is limited to first aid and there are no days away from work, job transfer, or job restriction, the case should not be recorded in the OSHA 300 log. The case is not recordable even if the first aid is administered at a health clinic, emergency room, hospital, or other medical treatment facility.
First aid treatment is defined as:
- Visits to a physician or other licensed health care professional solely for observation or counseling
- Diagnostic procedures, such as X rays and blood tests
- Use of nonprescription medications
- Cleaning and flushing, or soaking wounds on the surface of the skin
- Using wound coverings, such as bandages, etc.
- Using any nonrigid means of support
- Using temporary immobilization devices while transporting victims (splints, collars, back boards, etc.)
- Drilling of fingernails or toenails to relive pressure or draining fluid from a blister
- Removing splinters or foreign materials from areas other than eyes by irrigation, tweezers, swabs, etc.
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- Removing foreign objects from eyes using only irrigation or cotton swab
- Using eye patches or finger guards
- Nontherapeutic massages
- Using hot or cold therapy
- Giving fluids for relief of heat illness
- Administering tetanus immunizations
Tomorrow, we’ll conclude with a warning from an attorney about the possibility of injury and illness records being used as evidence to prove violation of safety and health standards.