When Does OSHA Require Me to Track or Record an Injury?

So a worker got a cut. They washed their hands, threw on a bandage and went back to what they were doing. Seems pretty simple, right? Well, technically, cleaning the cut and applying a bandage make this a first aid incident...the question now is does it need to be recorded?

Many employers will tell you that OH&S is rarely simple, because it isn't always immediately obvious whether or not an injury needs to be recorded under OSHA regulations. Though it seems intuitive to record any incident that requires any level of first aid, only severe injuries and illnesses actually need to be logged.

OSHA has two categories of incidents: Recordable Injuries and Illnesses, and First Aid. While the two are significantly different, confusion between the two tends to occur when procedures or treatments that are usually administered by a medical professional, are considered as first aid.

How Does OSHA define recordable injuries?

According to the United States Department of Labor, most organizations with 10 or more employees are required to record serious injuries, but not first aid incidents. When looking at the OSHA requirements, the list of criteria that qualifies an illness or injury as being recordable is relatively short and to the point.

OSHA defines recordable injuries and incidents as:

• Any work-related fatality. This one is pretty self explanatory.
• Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job. You must record any injuries or illnesses that require significant modification to your work.
• Any work-related injury or illness requiring medical treatment beyond first aid. This one might lead to some confusion, we'll come back to it in a minute.
• Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums. These are serious conditions that require immediate and often continued medical attention.
• There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis. These specific criteria can be found here.

That's all relatively straight forward, right? So let's dive into first aid injuries and illnesses and see if we can make some sense of those.

What is an OSHA first aid injury?

Many people consider first aid to be a treatment that can be administered on site by a trained colleague. If you think about it, most first aid classes teach you the quick fix for a number of injuries, and tell you to call for help immediately. Surely once medical intervention is required, it is no longer a first aid incident right?

Well, with OSHA regulations, this isn't necessarily the case. In fact, there are many different views of what first aid actually encompasses, and what your company considers a recordable incident may be different from the OSHA regulations. It is therefore very important to know specifically what OSHA classifies as a first aid incident.

While it is possible that certain Health and Safety teams might have more advanced first aid training, even injuries for which medical intervention is required could count as unrecordable first aid injuries.

• 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 record keeping 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.

It is also important to note that anything other than the specific practices we just looked at are considered to be recordable incidents. However, this can also be confusing if there are multiple treatment options for the same injury.

Take these examples from Ergoscience, which published a similar blog post back in 2015:

While a wound closed with butterfly bandages is considered a first aid incident, closing that same wound with sutures would make it a serious, recordable injury.

and,

Hot or cold therapy is designated as first aid. However, while compresses, soaking, and non-prescription skin creams or lotions that produce a localized heating affect are first aid, more advanced heat therapies, such as whirlpool treatments or ultrasound treatments are not. They are classified as physical therapy, which constitutes medical treatment.

Basically, the exact same injury, just treated two different ways can mean the difference between recording the injury, and just chalking it all up to a bad day at the office. We tend to veer on the side of caution, but in this case it would be left up to the company's policy on injuries or the worker's discretion which treatment option he or she would prefer.

So what does all this mean?

Serious recordable incidents under OSHA Regulations include anything that involves lost time/modified work, lost limbs, loss of life and loss of consciousness. It also encompasses serious workplace illnesses, such as cancer related to chemicals or substances related to the job, stitches and non-rigid supports.

Most other injuries (the a few exceptions) fall under the the first aid umbrella, even if they require medical intervention.

If you have any doubts as to whether or not an injury is recordable or not, the regulations are online and all changes are updated regularly.

Keep in mind that while you can file a petition with OSHA to track injuries and illnesses slightly differently, it you will want to stick to the official regulations until it is approved. In the event the request is delayed or denied, you'll want to make sure you have the proper documentation if they request to see your records in the meantime.

*Edited title to more accurately reflect content.