This pamphlet summarizes the OSHA recordkeeping requirements of 29 CFR Part 1904, and provides basic instructions and guidelines to assist employers in fulfilling their recordkeeping and reporting obligations. The OSHAs recording standards mandate that severe injuries and illnesses must be reporteâ¦ Employers must also provide an annual summary of injuries (OSHA Form 300A) that must be posted in a visible location in the workplace. An employer 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. In light of these considerations, OSHA is exercising its enforcement discretion in order to provide certainty to employers and workers. Visits to a physician or other licensed health care professional solely for observation or counseling; The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (. A few weeks ago, OSHA issued general guidance on COVID-19 for employers. In determining whether an employer has complied with this obligation and made a reasonable determination of work-relatedness, CSHOs should apply the following considerations: If, after the reasonable and good faith inquiry described above, the employer cannot determine whether it is more likely than not that exposure in the workplace played a causal role with respect to a particular case of COVID-19, the employer does not need to record that COVID-19 illness. Because this is an illness, if an employee voluntarily requests that his or her name not be entered on the log, the employer must comply as specified under 29 CFR Â§ 1904.29(b)(7)(vi). OSHA Form 301 If the restriction from you or the physician or other licensed health care professional keeps the employee from performing one or more of his or her routine job functions, or from working the full workday the injured or ill employee would otherwise have worked, the employee's work has been restricted and you must record the case. An employee's COVID-19 illness is likely not work-related if she is the only worker to contract COVID-19 in her vicinity and her job duties do not include having frequent contact with the general public, regardless of the rate of community spread. What is meant by "routine functions"? (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 (. â Some cases may be OSHA recordable, but not compensable. Background. Cal/OSHA COVID-19 Guidance and Resources Workplace safety and health regulations in California require employers to take steps to protect workers exposed to infectious diseases like the Novel Coronavirus (COVID-19), which is widespread in the community. If you or a physician or other licensed health care professional recommends a work restriction, is the injury or illness automatically recordable as a "restricted work" case? WASHINGTON, April 13âAssociated Builders and Contractors Vice President of Health, Safety, Environment and Workforce Development Greg Sizemore today issued the following statement on the release of Occupational Safety and Health Administrationâs April 10 guidance on recording cases of COVID-19: âABC is pleased OSHA has clarified its position regarding the recordability of COVID-19 â¦ We will tell you exactly which accidents should be reported in your safety records and which donât need to be. Directorate of Enforcement Programs, Revised Enforcement Guidance for Recording Cases of Coronavirus Disease 2019 (COVID-19). In such a case, entering 180 in the total days away column will be considered adequate. REGIONAL ADMINISTRATORS To be recordable, the entertainment activity must be one that the employee engages in at the direction of the employer. Back to text,  Under 29 CFR Â§ 1904.7, an employer 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. Please frequently check OSHA's webpage at www.osha.gov/coronavirus for updates. WARNING: DO NOT MIX OSHA's recordkeeping rules state that the use of a prescription drug is recordable as medical treatment. â Some cases may be compensable, but not OSHA recordable. What is "first aid"? â Some cases may be OSHA recordable and compensable. Reporting a serious illness is not an â¦ OSHA Medical Treatment vs. First Aid (52.3 KiB, 1,264 hits) Want to know what is considered first aid in the eyes of OSHA 29 CFR 1904.7.b.5.ii? OSHA Recordability Comparison Chart. Employers with fewer than 10 employees or who belong to certain low-hazard industries may be exempt from OSHA recording guidelines. GUIDELINES FOR DETERMINING RECORDABILITY ON OSHA LOG 300 . If the answer to both of these questions is "Yes," then the case does not involve a work restriction and does not have to be recorded as such. Join us in our effort of reducing safety and health hazards in your workplace. One of the most confusing aspects of OSHA recordkeeping is determining if an injury or illness is recordable based upon the medical treatment. Basic requirement. What is the definition of medical treatment? CSHOs will generally refer to CPL 02-00-135, Recordkeeping Policies and Procedures Manual (Dec. 30, 2004), and CPL 02-00-163, Field Operations Manual (Sept. 13, 2019), Chapters 3 and 6, as applicable. STATE PLAN DESIGNEES, LEE ANNE JILLINGS, Acting Director As discussed below, OSHA is exercising enforcement discretion regarding work-relatedness in the context of employee COVID-19 illness. Business-related entertainment activities that are undertaken voluntarily by an employee in the exercise of his or her discretion are not covered by the rule. Recording a COVID-19 illness does not, of itself, mean that the employer has violated any OSHA standard. Back to text,  www.osha.gov/enforcement/directives/cpl-02-00-163. For the purposes of Part 1904, medical treatment does not include: "First aid" as defined in paragraph (b)(5)(ii) of this section. In this article, weâll explain to you exactly what a recordable injury or illness is and which establishments have to do the recording. An employee's COVID-19 illness is likely work-related if it is contracted shortly after lengthy, close exposure to a particular customer or coworker who has a confirmed case of COVID-19 and there is no alternative explanation. on the OSHA 300 Log and the OSHA 300-A Summary. OSHA published a Final Rule to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to â¦ Download OSHAâs first aid list below. This one-time treatment, and followup If the answer to one or both of these questions is "No," the case involves restricted work and must be recorded as a restricted work case. This OSHA recordability guide is here to prevent that headache (which by the way, is not an OSHA recordable incident) and ensure that you know everything you need to know about OSHA recordable criteria to keep you out of trouble! Attend this complimentary Virtual Event on OSHA Recordability & COVID-19 to learn what recent changes mean for recordkeeping! You are not required to keep track of the number of calendar days away from work if the injury or illness resulted in more than 180 calendar days away from work and/or days of job transfer or restriction. Directorate of Technical Support and Emergency Management No. Note to § 1904.7: OSHA believes that most significant injuries and illnesses will result in one of the criteria listed in § 1904.7(a): death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness. Using a non-prescription medication at nonprescription 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. Because of the difficulty with determining work-relatedness, OSHA is exercising enforcement discretion to assess employers' efforts in making work-related determinations. When is an injury or illness considered work-related? OSHA Tab Guide doc; Worker's Compensation Entry vs. OSHA Recordkeeping doc; Lost and Restricted Days docx; OSHA Reporting Information pdf; Recordability-First Aid vs Medical Treatment pdf; Use the OSHA recordable decision tree. We have described each log and their requirements below. COVID-19 illnesses are likely work-related when several cases develop among workers who work closely together and there is no alternative explanation. In most cases the agency never sees the records, but employers must have them readily accessible and provide them to OSHA inspectors when asked to do so as part of a jobsite inspection. See www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.7. Is there a limit to the number of days away from work I must count? Organizations covered under OSHA must complete these recordkeeping logs for all work-related OSHA recordable injury and illnesses. In addition, there are some significant progressive diseases, such as byssinosis, silicosis, and some types of cancer, for which medical treatment or work restrictions may not be recommended at the time of diagnosis but are likely to be recommended as the disease progresses. [43 FR 31329, July 21, 1978; 62 FR 44552, Aug. 22, 1997; 66 FR 6126, Jan. 19, 2001], Occupational Safety & Health Administration. This instruction provides guidance to OSHA's compliance personnel about inspection policies and procedures concerning worksites in an employee's home. OSHA Injury and Illness Recordkeeping and Reporting Requirements. The following additional specific enforcement guidance is provided for CSHOs: If you have any questions regarding this policy, please contact Elizabeth Grossman, Director of the Office of Statistical Analysis, at (202) 693-2225. cc:Â Â Â Â Â Â DCSP AGENDA Requirements of OSHA recordkeeping Revisions to OSHA Recordkeeping and Reporting Questions & Answers 2. Note: These Interim Guidelines Are Subject to Change as the Situation Evolves. COVID-19 is a respiratory illness and should be coded as such on the OSHA Form 300. Recordable (Medical Treatment) Non-Recordable (First Aid) Cuts Lacerations Punctures Abrasions. Back to text, Occupational Safety & Health Administration, Occupational Safety and Health Administration, www.osha.gov/memos/2020-04-10/enforcement-guidance-recording-cases-coronavirus-disease-2019-COVID-19, www.cdc.gov/coronavirus/2019-ncov/php/reporting-pui.html, www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.5, www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.7, www.osha.gov/enforcement/directives/cpl-02-00-135, www.osha.gov/enforcement/directives/cpl-02-00-163, Severe Storm and Flood Recovery Assistance. What is an OSHA Log? All these factsâincidence, adaptation, and the return of the workforceâindicate that employers should be taking action to determine whether employee COVID-19 illnesses are work-related and thus recordable. The Occupational Safety and Health Administration (OSHA) requires employers with more than 10 employees to recordânot reportâwork-related injuries and illness. For OSHA injury and illness recordkeeping purposes, self administered treatment by an employee is considered medical treatment only when it is under the direction and made available by the employer or a health care professional (page 14, Ergonomics Program Management Guidelines for Meatpacking Plants). Cases that are OSHA recordable must be recorded on an OSHA-standardized Log of Work-Related Injuries and Illnesses (OSHA Form 300). Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. 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