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Occupational Safety and Health Administration (OSHA)

What is an OSHA recordable?

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2009-11-06 03:06:21
2009-11-06 03:06:21
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An OSHA recordable is an injury, illness, or death that OSHA deems to be recordable under its recordkeeping regulations.

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The answer to your question is that giving a medication, dose or a treatment that "requires a prescription" makes an injury "recordable" under OSHA guidelines. Therefore a "prescription" for 200mg ibuprofen is not recordable unless you tell the patient to take 3 pills at a time (a prescription dose of a non prescription medication.) Now, 400mg ibuprofen is not a prescription dose but is not available over the counter so likely would be considered a "prescription" medication. Confusing, huh?

So when you gave that injured worker 400mg of ibuprofen that night that did not cause the injury to be listed as recordable but prescribing the antibiotic did. (I hope it was more than a scratch.)

Next, duty status: Restricting duty will usually make an injury recordable under OSHA guidelines but not in all cases.

First you may restrict the workers duty for the balance of his shift on the "day of injury" without incurring recordability. The "day of injury" is defined by OSHA as well and occasionally subject to interpretation. If the injury results from trauma, the day of injury is the day of the trauma and the subsequent shift. So our night workers who are injured before midnight may be restricted after midnight without penalty if the restriction is limited to the current work shift. The TX DWC 73 form in this case would have both the restricted and unrestricted boxes checked with the appropriate dates clearly noted. It is a good idea to write "balance of shift only" in the notes section of restrictions.

A worker who reports his traumatic injury occurred on a prior date establishes that date as the "date of injury" and may not be restricted balance of shift without triggering recordability. (Remember that this worker may have been doing full duty up to the time of the visit and may deserve a trail of treatment without restrictions initially.) Be aware that we all will use the date of injury for identification and tracking so it should be consistent with the employers and insurers records as well so document the incident carefully. You may be asked to defend your choice of DOI.

When a worker reports symptoms that have appeared gradually and the medical determination is that the injury is a result of "cumulative trauma" the date of the first medical visit and diagnosis becomes the "date of injury." Work related soreness is not always "an injury" but when an employee is brought to us it becomes an injury. Be sure to counsel workers that when the work is hard, soreness can be a daily fact of life especially during an adjustment period when the work or the pace is changing.

Restrictions that do not impact the "essential functions" of an employee's job do not trigger recordability. For example, a secretary who is told not to lift 50 pounds would not generally trigger recordability. Putting that restriction onto her duty slip might trigger an unpleasant response from her safety supervisor if he does not understand OSHA very well (and many do not.)

"Lost time" under OSHA results when restrictions are so consequential that the employee should not be at work. This is rarely a medical determination with the injuries we treat and applies more to patients that have required hospitalization or surgery. Even so, many workers can undergo day surgeries and return to restricted duties without lost time if the consultants understand how to work with the system. Employees may even be in a safer and more supervised environment than they would be at home.

"Death" in the workplace is the highest level of recordability and usually OSHA will be onsite within 24 to 48 hours to investigate the circumstances surrounding these tragedies.

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