Written by Steve Hudgik
OSHA standard 1904.7 specifies the injury and illness records (the OSHA Log) that must be maintained. The opening paragraph states:
1904.7(a) Basic requirement. You must consider an injury or illness to meet the general recording criteria, and therefore to be 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, or loss of consciousness. You must also consider a case to meet the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
The OSHA Form 300, the "Log Of Work-Related Injuries And Illnesses" (the OSHA Log) is used to record and classify work-related injuries and illnesses, and to record the extent and severity of each. When an incident occurs, use the OSHA Log to record specific details about what happened and how it happened.
A separate OSHA Log (Form 300A) is used to summarize the totals for the year in each category. At the end of the year, post the summary in a visible location so that your employees are aware of the injuries and illnesses occurring in their workplace.
Employers must keep an OSHA Log for each establishment or site. If you have more than one establishment, you must maintain a separate OSHA Log and summary for each physical location that is expected to be in operation for one year or longer.
Workplace injury and illness record keeping is critical for several reasons:
This may seem obvious, but write legibly. Take the time to write clearly and use whatever space is necessary to completely describe what happened.
Injuries treated by first aid alone, such bandaging a minor cut, are not recordable if there was no lost time from work, nor any work restrictions. However, record these minor injuries using a list separate log from your OSHA Log. While minor, these injuries can provide valuable information to help you improve safety.
OSHA Log Question - Is an exercise regime considered as first aid or medical treatment?
Question: Does an exercise regime directed by a Certified Athletic Trainer (ATC) constitute "first aid" or "medical treatment" for OSHA Log purposes?
OSHA considers therapeutic exercise as a form of physical therapy. It is not included on the list of first aid treatments in Section 1904.7(b)(5)(ii). However, physical therapy and chiropractic treatment are considered medical treatment for OSHA Log record-keeping purposes.
If a treatment is administered as a purely precautionary measure to an employee who does not exhibit any signs or symptoms of an injury or illness, the case is not recordable in the OSHA Log. For a case to be recordable, an injury or illness must exist. Also, if an employee has an injury or illness that is not work-related, (e.g., the employee is experiencing muscle pain from home improvement work) the administration of exercise does not make the case recordable either.
Each incident is recorded in just one classification in your OSHA Log. Workplace injuries and illnesses should be classified using only the most serious outcome. For example, a day away from work is more serious that multiple days of work restrictions. However, all outcomes, with day counts, should be recorded in the OSHA Log.
OSHA Log Question: Updating the OSHA Log due to a change in the classification of a previously recorded injury.
Question: OSHA standard 1904.33 states that an employer must update the OSHA Log to include any changes in the description of a recorded injury or illness. It is common for a plant nurse initially to describe a condition as a "strain." When the employee is then seen by outside treating physicians, the physicians typically make a formal diagnosis, such as "tendonitis," "tenosynovitis," "epicondylitis," etc. If an employee is evaluated by a number of different physicians, the same condition may be given a number of different diagnoses. Sometimes the diagnosis will be fairly obscure, such as "subacromial impingement," which most lay people would not understand.
Are employers required to change an initial Column F description of "strain" to the most up-to-date diagnosis? Would the failure to enter such a formal diagnosis in Column F result in the issuance of a citation?
Answer: Section 1904.33 deals with the retention and updating of the OSHA Part 1904 records after they have been created and summarized. This requires the employer to update the entries on the OSHA 300 Log and to show changes that have occurred to previously recorded cases.
In this case the employer would be required to update the entry in the OSHA Log if, based on new information, the diagnosis of the injury actually changed from the original entry. In other words, the log must be updated if the injury was originally diagnosed as a "strain" but was later determined to be a "fracture." On the other hand, an employer need not update the OSHA Log if a physician or other licensed health care professional merely refers to an injury or illness by a different or more medically technical name. In such a case, failure to update an entry would not materially impair the understandability of the nature of hazards, injuries and illnesses in the workplace.
Each incident must be be recorded in your OSHA Log for the the year in which the injury happened. Even when the effects of the injury continue into another year, that information should continued to be recorded in the OSHA Log for the year in which the injury happened.
For your OSHA Log count all days, not just scheduled work days, when counting days away from work; days when work restrictions applied; or days of working a different job. When employees normally work on weekends, then weekend days must also be counted in the OSHA Log.
OSHA Log Question – Should a vacation day be recorded on the OSHA Log when it was recommended the employee return to work?
What Happened: An employee incurred a work-related injury on a Saturday, but did not think it was severe enough to see a doctor. He was not scheduled to work on Sunday, but did report to work on Monday. After working six hours, the employee left work and sought treatment at an emergency room for the injury from Saturday. After receiving treatment, the emergency room physician released the employee to return to work the next day (Tuesday), which was the employee's next normally scheduled workday, with work restrictions.
On Tuesday, prior to his next shift, the employee contacted the employer and stated that he was in so much pain he needed to see a doctor right away. The employee requested to use a vacation day for the time off. The employer approved the request, and the employee saw the doctor and was again released to return to work with restricted duty. However, because the employee had already been approved to take a full vacation day, he did not return to work until Wednesday.
Question 1: Should the absence on Tuesday be recorded in the OSHA Log (OSHA 300 Log) as a day away from work or just as a day of restricted work?
Answer: OSHA standard 1904.7(b)(3) states that work-related injuries and illnesses involving one or more days away from work must be recorded on the OSHA Log. Section 1904.7(b)(3)(iii) states that if a physician or other licensed health care professional recommends the employee can return to work, but the employee stays at home, the case does not have to be recorded as a day away from work.
In the scenario described above, the physician recommended that the employee could return to work with restricted work duties. However, the injured employee decided not to return to work until Wednesday. Therefore, the day in question (Tuesday) should be recorded as a day of restricted work activity.
Note: OSHA does not consider time spent traveling to and from medical evaluations as either days away from work or restricted work activity. Instead, the focus is on whether the injured or ill employee needs days away from work or restricted work activity to recuperate from the work-related injury or illness. Classification of the day off as a "vacation day" is not relevant to this determination.
Question 2: Does it make a difference if the employee has been released to return to work with restricted work, but is allowed to take the day off as an unexcused absence?
Answer: You must record the number of calendar days the employee was unable to work (days away or restricted work activity) as a result of the injury or illness in your OSHA Log. If the employer determines that the employee needed time off because of their severe pain and was unable to work, the case should be recorded in the OSHA Log as a day away from work. On the other hand, if the employer determines that the injured employee was able to come to work, and perform restricted work, the case should be recorded in the OSHA Log as restricted work activity.
Question 3: Would it make a difference if the employee did not see the doctor on the Tuesday he took the day off?
Answer: If the employee had not seen the doctor on Tuesday, that day should be counted in the OSHA Log as a day away from work, if the employer determines the employee cannot work because of the injury.