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.
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.
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.
Under 29 CFR 1904, covered employers are required to prepare and maintain records of serious occupational injuries and illnesses using the OSHA 300 Log. This task is easy using the Incident Tracking tool in the J. J. Keller® SAFETY MANAGEMENT SUITE. Let this tool help you track recordable incidents to help identify hazards and trends.
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