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Key OSHA Recordkeeping Concepts Employers Need to Know

August 23rd, 2024

An intuitive grasp of Occupational Safety and Health Administration (OSHA) workplace injury and illness recordkeeping and reporting concepts makes it easier for employers to comply. With that in mind, we recently welcomed Ryan Burr of Burr Consultants LLC to our Risk Control Webinar Series to cover recordable case criteria. Below are some of the main concepts Burr shared.

Burr began by noting that OHSA prescribes recordkeeping requirements for employers with more than 10 employees in the event of work-related deaths and serious injuries and illnesses. Employers in certain industries are partially exempt.

Burr added that injury and illness cases are recordable if any of the following criteria apply to an employee:

  • Loses consciousness.
  • Receives medical treatment rather than first aid.
  • Misses any workdays.
  • Has their work restricted.
  • Has to be transferred to a different job.

Decision tree for recording injury and illness cases. (Burr Consultants LLC)

Employers covered by the rule must record injuries and illnesses in the OSHA 300 Log within seven calendar days of the injury or its medical diagnosis. Also, they must post the OSHA 300A Summary in the workplace between Feb. 1 and April 30 of the year after the year covered by the form.

9 Work-relatedness Exceptions

Burr pointed out that an injury or illness is considered work-related if a workplace event or exposure caused the condition, contributed to the condition, or significantly aggravated a pre-existing condition. There are nine work-relatedness exceptions.

No. 1: General Public

An employee is injured in the work environment as a member of the general public, e.g., on their day off.

No. 2: Unrelated to Work

Conditions surface at work but are solely the result of events or exposures unrelated to work, e.g., pre-existing asthma.

No. 3: Voluntary Activities

An injury occurs during voluntary activities in the work environment, such as an exercise class.

No. 4: Food or Drink

An employee develops a condition from eating, drinking, or preparing their own food or drink.

The following scenarios count as work-related: Food contamination occurred at work, the employer provided contaminated food, or the employee developed a food-related illness after dining with a customer.

No. 5: Personal Tasks

An injury or illness results from an employee performing personal tasks at work, such as fixing a household appliance.

No. 6: Personal Care or Self-Harm

A condition results from personal grooming, self-medication, or is intentionally self-inflicted.

No. 7: Commuting

A condition results from a motor vehicle accident on company property or while an employee commutes to or from a workplace. But an injury to an employee struck by a motor vehicle while retrieving an item from their car after parking at work would be considered work-related.

No. 8: Common Illnesses

Employees contract the common cold or flu “going around the office.”

No. 9: Non-Work-Related Mental Illness

A mental illness, unless a healthcare professional provides an opinion that it is work-related.

Recording Lost Workdays

Also, employers must record a case if a work-related injury or illness caused an employee to miss one or more workdays, Burr said. He also covered additional lost workday determination criteria:

  • Lost workdays start the day after the injury occurred or the illness began.
  • If medical treatment is not sought on the day of the incident, any lost workdays are not counted until a medical professional recommends time off work — even if the employee continues working.
  • Lost workdays do not include any days when an employee stays home despite a medical recommendation to work and appropriate work is available.
  • All calendar days the employee did not work — weekdays, weekends, holidays, etc. —count as lost workdays if a medical or para-medical professional determines that the employee could not have worked.
  • The maximum number of days in a lost workday case is 180. The days include lost workdays, restricted duty days, or a combination.
  • If an injured employee remains absent at the end of the year, the employer must estimate the number of expected lost workdays and update the log when the actual number becomes available.

OSHA’s site provides more details about its injury and illness recordkeeping requirements.

About the Webinar

This presentation was part of Captive Resources’ Risk Control Webinar Series — regular installments of webinars to educate the group captive members we work with on topics like workplace safety, organizational leadership, and company performance. The thoughts and opinions expressed in these webinars are those of the presenters and do not necessarily reflect Captive Resources’ positions on any of the above topics.

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