Q. If an employee is seen by a doctor and the only treatment was administering oxygen, would this be recordable under OSHA‘s record keeping requirements?
A. Administering oxygen is considered medical treatment and therefore, is recordable.
Q. Do you have to record unconsciousness that is a result of a preexisting illness such a diabetes or epilepsy?
A. Loss of consciousness would be recordable if the preexisting injury or illness would likely not have resulted in loss of consciousness except for an occupational event or exposure.
In other words, if one or more events or exposures in the work environment significantly aggravated a preexisting condition and caused unconsciousness, it would be recordable.
Q. An employee tripped over a pallet and fell on his shoulder. He went to an Urgent Care clinic and received an X-ray. He appears to be bruised, but no medication or treatment was administered. Is this a recordable incident?
A. X-rays for diagnosis only are not recordable. If the employee had no days away from work or restricted work, the incident is not recordable.
Q. One of our employees was diagnosed with carpel tunnel that was work related. Per company policy she saw our company doctor who didn’t concur with the prior diagnosis. Since there was apparently no injury can the name be removed from the OSHA 300 Log?
A. OSHA was asked a similar question, and here’s its answer:
Employer’s Question. Once an employer has recorded a case involving days away from work, restricted work or medical treatment and the employee has returned to his regular work or has received the course of recommended medical treatment, is it permissible for the employer to delete the Log entry based on a physician’s recommendation, made during a year-end review of the Log, that the days away from work, work restriction or medical treatment were not necessary?
OSHA’s Answer: The employer must make an initial decision about the need for days away from work, a work restriction, or medical treatment based on the information available, including any recommendation by a physician or other licensed health care professional. Where the employer receives contemporaneous recommendations from two or more physicians or other licensed healthcare professionals about the need for days away, a work restriction, or medical treatment, the employer may decide which recommendation is the most authoritative and record the case based on that recommendation. Once the days away from work or work restriction have occurred, or medical treatment has been given, however, the employer may not delete the Log entry because of a physician’s recommendation, based on a year-end review of the Log, that the days away, restriction, or treatment were unnecessary.
Q. An employee was injured on the job in 2009 and returned April 2010 without any restrictions. Three months later he went out again for 2 weeks due to pain from the previous injury. How do I record on the OSHA 300 log the days he has missed for 2010?
A. Enter the injury on the 300 log for 2009. Enter the total number of calendar days away from work including the two weeks the employee was out the second time. Injuries are recorded on the log for the year in which they occurred. You may stop counting at 180 days.
Q. We have an employee who has an allergy to one of the chemicals we use. This employee was put on a permanent restriction. I believe this is recordable on the OSHA log. But I can’t figure out how many days to put down for job transfer or restriction. The employee did not miss any days.
A. Here’s an excerpt from the recordkeeping regulations that should answer your question:
1904.7(b)(4)(xi) How do I count days of job transfer or restriction? You count days of job transfer or restriction in the same way you count days away from work, using § 1904.7(b)(3)(i) to (viii), above. The only difference is that, if you permanently assign the injured or ill employee to a job that has been modified or permanently changed in a manner that eliminates the routine functions the employee was restricted from performing, you may stop the day count when the modification or change is made permanent. You must count at least one day of restricted work or job transfer for such cases.