Injury and illness recordkeeping: What you don't know can hurt you

OSHA's requirements for recording work-related injuries and illnesses seem straightforward, but it's not always easy to determine if a case is recordable. When it comes to answering recordability questions, it's important to be aware of OSHA's definitions and interpretations. For example, if you're not aware of OSHA's definition of "work-relatedness," you may fail to record a case that the Agency considers recordable.

How does OSHA define a recordable injury or illness?

• Any work-related fatality.
• Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
• Any work-related injury or illness requiring medical treatment beyond first aid.
• Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
• There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.
   

How does OSHA define work-related?

The regulations at 1904.5 define work-related to mean that an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for injuries and illness resulting from events or exposures in the work environment unless an exemption, found in 1904.5(b)(2), specifically applies.

The work environment includes the establishment and other locations where one or more employees are working or are present as a condition of their employment.

The exemptions provided are very specific, and apply only under narrowly defined circumstances. The presumption is that any injury occurring in the work environment is work-related unless one of those exemptions applies.

A significant aggravation of a pre-existing condition includes situations where the employee needs a change in medical treatment, or requires days away or restrictions, that were not needed for the original condition.

Does the work environment extend to telecommuting?

When an employee is working on company business at home and reports an injury or illness to his or her employer, and the employee's work activities caused or contributed to the injury or illness, or significantly aggravated a pre-existing injury, the case is considered work-related and must be further evaluated to determine whether it meets the recording criteria. If the injury or illness is related to non-work activities or to the general home environment, the case is not considered work-related.