When does an abnormal condition become an injury?

Many employers must record certain work-related injuries on an OSHA 300 Log. OSHA defines an injury or illness as an “abnormal condition or disorder” like a cut, fracture, sprain, or skin rash. However, employees may experience muscle soreness or joint stiffness after a long day, or after performing a new task. Is this an “abnormal condition” that counts as an injury?

To address this, OSHA first noted that the definition of “injury” applies to potentially recordable cases, which (among other things) means the condition results in medical treatment, restrictions, lost days, or otherwise meets the recording criteria. If those outcomes don’t occur, the question of whether the condition qualifies as an injury should not be a concern — because the employer would not have to record the case.

Muscle soreness

An employer asked OSHA whether muscle soreness resulting from a new work activity would be considered an abnormal condition. OSHA noted that even though the agency broadly defines injury or illness, the definition captures changes that “reflect an adverse change in the employee’s condition that is of some significance.” Normal end-of-the-day tiredness would not be significant changes that rise to the level of an abnormal condition.

OSHA did warn, however, that an abnormal condition may exist without objective signs. For example, even if diagnostic testing (like an MRI) does not show anything unusual, an employee’s subjective pain could still indicate that an abnormal condition exists. If an employee experiences pain, tingling, numbness, or similar symptoms, OSHA considers this an indication of an abnormal condition.

However, OSHA also noted that employers are not required to record symptoms on the 300 Log. Even if work-related muscle soreness reaches the level of an abnormal condition, it would not be recordable if it does not meet any of the recording criteria (days away from work, restrictions, medical treatment, etc.).

For those reasons, employers should focus less on whether a injury exists, and more on whether the case is work-related and meets the recording criteria. If a work-related condition results in medical treatment (such as prescription medications), or if a health care professional recommends that the employee’s work be restricted, the case would be recordable.

Preventative restrictions

As noted, if a health care professional (HCP_ recommends restrictions, the case is probably recordable. But what if the HCP says the employee can perform all job duties? In that case, OSHA said that employers may assign restrictions to prevent a more serious condition from developing, without recording the case. Specifically, OSHA said that a case is not considered recordable if:

1. the employee experiences minor musculoskeletal discomfort, and
2. a health care professional determines that the employee is fully able to perform all routine job functions, and
3. the employer assigns a work restriction to that employee for the purpose of preventing a more serious condition from developing.

This exception applies only when all three conditions are met. However, it does allow employers to let a worker “take it easy” for a while without creating an obligation to record the case on the 300 Log.

Similarly, OSHA addressed a question on whether an employee who performs all job functions, but works at a slower pace, would be deemed to have restrictions. The answer was no, since reduced productivity is not considered restricted work, as long as the employee continues to perform all routine functions.