OSHA injury and illness recordkeeping conundrum

J.J. Keller & Associates
Tags: workplace safety

You are responsible for safety at your company. You also have responsibility for OSHA injury and illness recordkeeping for your workplace. Usually things are fairly straightforward.


But one day an employee comes into your office and tells you that they saw a doctor that day. The employee was given treatment and a prescription as a result of a workplace injury. However, the event that caused the injury actually occurred almost two months prior, in the previous year. At the time the injury occurred, the employee did not require and did not seek medical treatment.


Now what are you supposed to do? How does OSHA expect you to enter this into the 300 Log?


This situation is not as uncommon as one might think. If the injury resulted from a single event, use that date, even if the injury did not meet the recording criteria until a later time. In this case, it would be recorded on the prior year's log.


For example, an employee cuts his or her hand, but does not require medical treatment or otherwise meet the recording criteria. At a later date, the cut becomes infected and requires a prescription antibiotic. The case would be recorded using the date of the cut because the precipitating event can be identified.


If the injury or illness develops over time, such as carpal-tunnel syndrome, then the injury is recorded on the date it is diagnosed by a physician or other licensed health care professional. This is taken from 1904.7(b)(7), which requires recording significant cases, such as cancer, on the date of diagnosis when no specific date of onset can be determined.


KellerOnline has a number of features which can help you with your OSHA 300 Injury and Illness Log. First, you can keep all of your injury and illness records right on KOL through Interactive Tools, under Incidents (Form 300/301). You can create an individual record for each employee, and track all injuries and illnesses that employee may experience.


Also, KOL offers a Frequently Asked Questions - Recordkeeping (injury and illness) area which contains many of the most commonly asked questions regarding the 300 Log. Often you may find answers to your questions in this area.


Through KOL you can also access the OSHA Recordkeeping Handbook which contains not only the regulation, but provides frequently asked questions, OSHA letters of interpretations, and insight into OSHA's thinking on the related interpretations for the recording and reporting standard.


And, in case you missed it, we offered a webcast titled "Injuries and Illnesses in the Work Environment: What makes them OSHA-recordable?" That webcast, and all previous webcasts, are available to you in the webcast archive area of KellerOnline. Click here to view it.

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