OSHA Recordkeeping Handbook - Msabc.net

§1904.6…Under the OSHA recordkeeping system, theemployer is always the responsible party when itcomes to making the determination of the recordabilityof a given case. However, if OSHA did not establishconsistent new case determination criteria, asubstantial amount of variability would be introducedinto the system, which would undermine theAgency’s goals of improving the accuracy and consistencyof the Nation’s occupational injury and illnessdata….…”[A]dopt a definition for new case that requiresthe occurrence of a new work-related event to triggera new case. In the absence of this, the case would beconsidered recurring.” …OSHA agrees… that if nofurther event or exposure occurs in the workplace toaggravate a previous injury or illness, a new caseneed not be recorded. However, if events or exposuresat work cause the same symptoms or signs torecur, the final rule requires employers to evaluatethe injury or illness to see if it is a new case and isthus recordable.The OSHA statistical system is designed to measurethe incidence, rather than prevalence, of occupationalinjury and illness. Incidence measures capturethe number of new occupational injuries and illnessesoccurring in a given year, while prevalence measurescapture the number of such cases existing in agiven year (prevalence measures thus capture caseswithout regard to the year in which they onset).Prevalence measures would therefore capture allinjuries and illnesses that occurred in a given year aswell as those unresolved injuries and illnesses thatpersist from previous years. The difference is illustratedby the following cases: (1) A worker experiencesa cut that requires sutures and heals completelybefore the year ends; this injury would be capturedboth by an incidence or prevalence measure for thatparticular year. (2) Another worker retired last yearbut continues to receive medical treatment for awork-related respiratory illness that was first recognizedtwo years ago. This case would be captured inthe year of onset and each year thereafter until itresolves if a prevalence measure is used, but wouldbe counted only once (in the year of onset) if an incidencemeasure is used.Because the OSHA system is intended to measurethe incidence of occupational injury and illness, eachindividual injury or illness should be recorded onlyonce in the system. However, an employee can experiencethe same type of injury or illness more thanonce. For example, if a worker cuts a finger on amachine in March, and is then unfortunate enough tocut the same finger again in October, this worker hasclearly experienced two separate occupationalinjuries, each of which must be evaluated for itsrecordability. In other cases, this evaluation is not assimple. For example, a worker who performs forcefulmanual handling injures his or her back in 1998,resulting in days away from work, and the case isentered into the records. In 1999 this worker hasanother episode of severe work-related back pain andmust once again take time off for treatment and recuperation.The question is whether or not the newsymptoms, back pain, are continuing symptoms ofthe old injury, or whether they represent a new injurythat should be evaluated for its recordability as anew case. The answer in this case lies in an analysisof whether or not the injured or ill worker has recoveredfully between episodes, and whether or not theback pain is the result of a second event or exposurein the workplace, e.g., continued manual handling. Ifthe worker has not fully recovered and no new eventor exposure has occurred in the workplace, the caseis considered a continuation of the previous injury orillness and is not recordable….…The term “new case” tends to suggest to somethat the case is totally original, when in fact newcases for OSHA recordkeeping purposes includethree categories of cases; (1) totally new cases wherethe employee has never suffered similar signs orsymptoms while in the employ of that employer, (2)cases where the employee has a preexisting conditionthat is significantly aggravated by activities atwork and the significant aggravation reaches thelevel requiring recordation, and (3) previously recordedconditions that have healed (all symptoms andsigns have resolved) and then have subsequentlybeen triggered by events or exposures at work.Under the former rule and the final rule, both newinjuries and recurrences must be evaluated for theirwork-relatedness and then for whether they meetone or more of the recording criteria; when these criteriaare met, the case must be recorded. If the caseis a continuation of a previously recorded case butdoes not meet the “new case” criteria, the employermay have to update the OSHA 300 Log entry if theoriginal case continues to progress, i.e., if the statusof the case worsens. For example, consider a casewhere an employee has injured his or her back liftinga heavy object, the injury resulted in medical treatment,and the case was recorded as a case withoutrestricted work or days away. If the injury does notheal and the employer subsequently decides toassign the worker to restricted work activity, theemployer is required by the final rule to change thecase classification and to track the number of days of42OSHA RECORDKEEPINGHANDBOOK