One of the most common questions safety managers face is, "Do I need to put this on the OSHA log?" Over-reporting inflates your incident rates, potentially triggering OSHA inspections or costing you bids. Under-reporting can lead to massive fines. Here is how to navigate the gray areas.
The Three Basic Criteria
For an incident to be recordable, it must meet ALL THREE of the following criteria:
- 1. An injury or illness occurred.
- 2. It is work-related.
- 3. It meets one or more of the general recording criteria.
Determining Work-Relatedness
OSHA considers an injury or illness work-related if an event or exposure in the work environment either caused or contributed to the resulting condition, or significantly aggravated a pre-existing condition.
Compliance Tip
There are specific exemptions to work-relatedness, such as injuries occurring while an employee is eating food they brought from home, or injuries resulting solely from voluntary participation in a wellness program.
The General Recording Criteria
If the injury is work-related, it is recordable if it results in any of the following:
- Death
- Days away from work
- Restricted work or transfer to another job
- Medical treatment beyond first aid
- Loss of consciousness
- A significant injury or illness diagnosed by a physician or other licensed health care professional
First Aid vs. Medical Treatment
This is the most common area of confusion. OSHA has a strict, finite list of treatments considered "first aid." If a treatment is on this list, the case is NOT recordable (unless it meets other criteria like days away).
First aid includes:
- Using non-prescription medications at non-prescription strength
- Administering tetanus immunizations
- Cleaning, flushing, or soaking wounds on the surface of the skin
- Using wound coverings like bandages, Band-Aids, or gauze pads
- Using hot or cold therapy
- Using any non-rigid means of support (elastic bandages, wraps)
If a doctor prescribes a prescription medication, or recommends a non-prescription medication at prescription strength, it is considered medical treatment and the case becomes recordable.