OSHA Recordkeeping Handbook - Msabc.net

care professional, he or she may also be able to consultwith the health care professional about the workrelatednessof the particular case. If the employerdetermines, based either on his or her own findingsor those of the professional, that the symptoms aremerely arising at work, but are caused by some nonworkillness, then the case would not be recorded,under exception (b)(2)(ii) to the work-relatedness presumptionat Section 1904.5(b)(2) of the final rule.Similarly, if workplace events or exposures contributedonly insignificantly to the aggravation of aworker’s preexisting condition, the case need not berecorded under Section 1904.5(a) and Section1904.5(b)(3) of the final rule.The provisions of Section 1904.7(b)(7) of the finalrule thus meet the objectives of (1) capturing significantinjuries and illnesses that do not meet the othergeneral recording criteria of death, days away fromwork, restricted work or job transfer, medical treatmentbeyond first aid, or loss of consciousness; (2)excluding minor injuries and illnesses; (3) addressinga limited range of disorders; and (4) making it clearthat these injuries and illnesses must be work-relatedbefore they must be recorded.FREQUENTLY ASKED QUESTIONS: Section 1904.7 (OSHA Instruction, CPL 2-0.135, Chap. 5)Section 1904.7 General recording criteriaQuestion 7-1. The old rule required the recording ofall occupational illnesses, regardless of severity. Forexample, a work-related skin rash was recorded evenif it didn’t result in medical treatment. Does the rulestill capture these minor illness cases?No. Under the new rule, injuries and illnesses arerecorded using the same criteria. As a result, someminor illness cases are no longer recordable. Forexample, a case of work-related skin rash is nowrecorded only if it results in days away from work,restricted work, transfer to another job, or medicaltreatment beyond first aid.Question 7-2. Does the size or degree of a burndetermine recordability?Question 7-4. An employee hurts his or her left armand is told by the doctor not to use the left arm forone week. The employee is able to perform all of hisor her routine job functions using only the right arm(though at a slower pace and the employee is neverrequired to use both arms to perform his or her jobfunctions). Would this be considered restricted work?No. If the employee is able to perform all of his orher routine job functions (activities the employee regularlyperforms at least once per week), the casedoes not involve restricted work. Loss of productivityis not considered restricted work.Question 7-5. Are surgical glues used to treat lacerationsconsidered “first aid?”No. The size or degree of a work-related burn doesnot determine recordability. If a work-related first,second, or third degree burn results in one or moreof the outcomes in section 1904.7 (days away, workrestrictions, medical treatment, etc.), the case mustbe recorded.Question 7-3. If an employee dies during surgerymade necessary by a work-related injury or illness, isthe case recordable? What if the surgery occursweeks or months after the date of the injury or illness?If an employee dies as a result of surgery or othercomplications following a work-related injury or illness,the case is recordable. If the underlying injuryor illness was recorded prior to the employee’s death,the employer must update the Log by lining outinformation on less severe outcomes, e.g., days awayfrom work or restricted work, and checking the columnindicating death.No. surgical glue is a wound closing device. Allwound closing devices except for butterfly and steristrips are by definition “medical treatment,” becausethey are not included on the first aid list.Question 7-6. Item N on the first aid list is “drinkingfluids for relief of heat stress.” Does this includeadministering intravenous (IV) fluids?No. Intravenous administration of fluids to treatwork-related heat stress is medical treatment.Question 7-7. Is the use of a rigid finger guard consideredfirst aid?Yes. The use of finger guards is always first aid.Question 7-8. For medications such as Ibuprofen thatare available in both prescription and non-prescriptionform, what is considered to be prescription§1904.7OSHA RECORDKEEPINGHANDBOOK67