OSHA regulations require employers to prepare and maintain records of serious occupational injuries and illnesses. If you're a covered employer, you should be familiar with the OSHA 300 Log in which those records must be kept. However, deciding which on-the-job incidents are recordable and which are not can be confusing – and getting it wrong can cost businesses dearly in penalties and frustration.
How, then, should employers make accurate determinations as to what constitutes a first-aid injury and what is a recordable incident?
When Do Work-Related Injuries and Illnesses Constitute Reportable Incidents?
OSHA defines work-related injuries, illnesses, and fatalities are those in which an event or exposure in the work environment either caused, or contributed to, the condition. If such an event or exposure significantly aggravated a pre-existing injury or illness, this is also considered work-related.
Under OSHA record keeping standards, as of January 1, 2015, incidents that must be recorded include:
- All work-related fatalities
- All work-related in-patient hospitalizations of one or more employees
- All work-related amputations
- All work-related losses of an eye
- All work-related injuries and illnesses that result in days away from work, restricted work or transfer to another job, loss of consciousness, or medical treatment beyond first aid.
- Significant work-related injuries or illnesses diagnoses 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
About Non-Recordable, First Aid Incidents
Incidents that only require first aid treatment are not considered serious by the agency and do not need to be recorded. However, it is important to know that what you, your employees, and even many medical professionals and state workers' comp boards consider first aid may differ significantly from OSHA's definition of first aid practices, which explicitly include:
- Using a non-prescription medication at non-prescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes)
- Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment)
- Cleaning, flushing, or soaking wounds on the surface of the skin
- Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment)
- Using hot or cold therapy
- Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes)
- Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.)
- Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister
- Using eye patches
- Removing foreign bodies from the eye using only irrigation or a cotton swab
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
- Using finger guards
- Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes)
- Drinking fluids for relief of heat stress
Injuries or illnesses treated only with these OSHA approved methods are generally considered non-recordable first aid incidents – whether that treatment is provided on-site by a first aid officer or by a medical professional. However, straying away from these specific practices on the agency's list – considered 100 percent inclusive under their regulations – when treating a minor illness or injury constitutes medical treatment under OSHA standards, triggering recording requirements.
For instance, giving ibuprofen to an employee is first aid, so long as the dosage is 200-400 mg – the non-prescription dose. That same medication is considered medical treatment if you give it at prescription doses of more than 400 mg, making the incident recordable. While a wound closed with butterfly bandages is considered a first aid incident, closing that same wound with sutures would make it a serious, recordable injury.
Treating a worker who experiences minor musculoskeletal discomfort on-the-job with massage is considered first aid. However, the assignment of specific exercises designed to address that discomfort is, according to OSHA, considered physical therapy, which is classified as medical treatment and would create an obligation to record. However, job-specific exercises – ones that anyone doing the job should be doing to prevent injury – would not be classified as medical treatment. Exercises designed to prevent injury – administered to workers who show no signs of musculoskeletatal injuries – is not considered medical treatment as part of a workplace wellness/ergonomics program.
Hot or cold therapy is designated as first aid. However, while compresses, soaking, and non-prescription skin creams or lotions that produce a localized heating affect are first aid, more advanced heat therapies, such as whirlpool treatments or ultrasound treatments are not. They are classified as physical therapy, which constitutes medical treatment.
Keeping track of OSHA's Standard Interpretations, published regularly on their website, can help clarify what is considered as first aid and what is not as well as keep you abreast of changes in the agency's classifications. For instance, OSHA once classified use of Kinesiology tape as medical treatment, whereas wrapping the same exact injury with an Ace bandage would constitute first aid. That interpretation changed in July 2015, classifying kinesiotaping as a non-rigid means of support that qualifies as first aid.
The bottom line is that treating a simple first aid incident by any other means than those specifically classified as first aid transforms that incident into one that must be recorded in your OSHA 300 Log – an important technicality to be aware of to avoid inadvertently running afoul of OSHA record keeping requirements.