OSHA Recordable or First Aid Only? The Manager's Dilemma.

Jeff Anderson
Safety Consultant

As a manager, few things are worse than getting that phone call saying one of your people has been injured. So many questions come to mind. What happened? How serious is it? Who needs to be notified? All of these thoughts spring to mind along with a hundred other questions.

It’s always a relief when you learn that it isn’t a serious injury. But that just raises more questions. Do they need outside medical care? How do I know if I need to send them to the doctor? Is this a recordable injury? How will this affect my OSHA Recordable Rate? It can sometimes be confusing as to what constitutes an OSHA recordable injury. Serious injuries are obvious. But what about those injuries that are less obvious...the mild strain or small contusion, are they recordable? 

OSHA states that a recordable injury or illness is one that requires medical treatment beyond first aid, as well as one that causes death, days away from work, restricted work or transfer to another job, or loss of consciousness. Time spent at the initial doctor visit for observation or diagnostics to determine if an injury or illness is present is not considered medical treatment beyond first aid. In short, just because an employee goes to the clinic to be checked out does not necessarily make it an OSHA Recordable injury. It’s treatment beyond what is considered first aid that makes it required to go on the OSHA log.

First aid treatments include the following:

  • Using a nonprescription medication at nonprescription strength
    (For medications available in both prescription and nonprescription form, a recommendation by a physician or other licensed health care professional to use a nonprescription medication at prescription strength is considered medical treatment for record-keeping 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, or using butterfly bandages or Steri-Strips™ (Other wound closing devices such as sutures and staples are considered medical treatment)
  • Using hot or cold therapy
  • Using any nonrigid means of support, such as elastic bandages, wraps or nonrigid back belts (Devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for record-keeping purposes)
  • Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards)
  • 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 is considered medical treatment for record-keeping purposes)
  • Drinking fluids for relief of heat stress

If the injury requires treatment that is more than this list, it's beyond first aid and must be included in your company's OSHA 300 log.

Now that you know what makes an injury OSHA recordable how do you know if medical attention is required? Emergency situations are obvious, but what about those not so obvious sprains and strains? You want to take care of your people, but not create claims where one doesn’t need to be. It’s a dilemma that many managers face.

Many companies opt for an all or nothing approach. If an employee reports an injury they are sent to the clinic for evaluation. After all, how is a non-medical professional supposed to know if an injury needs further attention? The problem with this approach is that it will invariably drive up OSHA recordable numbers unnecessarily. Once an employee goes to a clinic, the likelihood that the injury will become recordable goes sky high. Clinics tend to err on the side of caution and often prescribe medication or take an employee off work for a few days making what might have been a first aid only claim OSHA recordable.

So what’s the solution? Larger companies like oil refineries and chemical plants have their own on-site medical clinic that can evaluate injuries and give proper care with an eye toward keeping outside forces from driving up their OSHA numbers and claim costs.  However, for the small company, this is not practical.

At The Gibraltar Group, we have partnered with Medcor for 24/7 injury triage and reporting. The benefits of Medcor service for the small business include:

  • Employees receive immediate attention from medical professional, toll-free, 24/7
  • Injuries receive appropriate treatment right away
  • Unnecessary doctor visits are avoided, reducing unnecessary claims and their associated fees
  • When off-site care is necessary, employees are guided to the employer’s in-network panel of providers
  • Supervisors are freed from making medical decisions
  • Liability for triage decisions transfers from the employer to Medcor
  • Complete documentation of call and its result is available to your company

As a manager, you want your people getting the medical care they need and deserve. Often times, injuries are pretty straightforward. But when they are not, its important to be armed with the knowledge and tools to control your company's claims properly. After all, one more OSHA recordable injury can be the difference between your company being cleared for work as a contractor and not making the cut.