OSHA Recordkeeping Handbook - denix

estricted work. If the case is a previous work-relatedinjury that did not meet the recording criteria andthus was not recorded, future developments in thecase may require it to be recorded. For example, anemployee may suffer an ankle sprain tripping on astep. The employee is sent to a health care professional,who does not recommend medical treatmentor restrictions, so the case is not recorded at thattime. If the injury does not heal, however, and a subsequentvisit to a physician results in medical treatment,the case must then be recorded….…In other words, a safety and health analysisshould give less weight to an injury or illness thathas a clear and relatively quick recovery withoutimpairment of any kind and an injury or illness that ischronic in nature or one that involves recurringepisodes that are retriggered by workplace events orexposures.Ignoring the fact that an occupational injury or illnessis a recurrence occasioned by an event or exposurein the workplace would result in an underestimateof the true extent of occupational injury and illnessand deprive employers, employees, and safetyand health professionals of essential information ofuse in illness prevention. The other extreme, requiringemployers to record on-going signs or symptomsrepeatedly, even in the absence of an event or exposurein the workplace, would result in overstating theextent of illness. In terms of the recordkeeping system,deciding how most appropriately to handle newcases requires a balanced approach that minimizesboth overrecording and underrecording. OSHA hasdealt with this problem in the final rule by carefullydefining the circumstances under which a chronicand previously recorded injury or illness must beconsidered closed and defining the circumstancesunder which a recurrence is to be considered a newcase and then evaluated to determine whether itmeets one or more of the recordability criteria….…The final rule uses one set of criteria for determiningwhether any injury or illness, including amusculoskeletal disorder, is to be treated as a newcase or as the continuation of an “old” injury or illness.First, if the employee has never had a recordedinjury or illness of the same type and affecting thesame part of the body, the case is automaticallyconsidered a new case and must be evaluated forrecordability. This provision will handle the vastmajority of injury and illness cases, which are newcases rather than recurrences or case continuations.Second, if the employee has previously had a recordedinjury or illness of the same type and affecting thesame body part, but the employee has completelyrecovered from the previous injury or illness, and anew workplace event or exposure causes the injuryor illness (or its signs or symptoms) to reappear, thecase is a recurrence that the employer must evaluatefor recordability.The implementation section of Section 1904.6describes these requirements and includes explanationsapplying to two special circumstances. In thefirst case, paragraph 1904.6(b)(1) the employee hasexperienced a chronic injury or illness of a type thatwill progress regardless of further workplace exposure.Cases to which this provision applies are serious,chronic illness conditions such as occupationalcancer, asbestosis, silicosis, chronic beryllium disease,etc. These occupational conditions generallycontinue to progress even though the worker isremoved from further exposure. These conditionsmay change over time and be associated with recurrencesof symptoms, or remissions, but the signs(e.g., positive chest roentgenogram, positive bloodtest) generally continue to be present throughout thecourse of the disease.The second kind of case, addressed in paragraph1904.6(b)(b)(2), requires employers to record chronicillness cases that recur as a result of exposures in theworkplace. These conditions might include episodesof occupational asthma, reactive airways dysfunctionsyndrome (RADS), or contact allergic dermatitis, forexample.Paragraph 1904.6(b)(3) recognizes the role ofphysicians and other licensed health care professionalsthat the employer may choose to rely on whentracking a “new case” or making a continuation of anold case determination. If a physician or otherlicensed health care professional determines that aninjury or illness has been resolved, the employermust consider the case to be resolved and record asa new case any episode that causes the signs andsymptoms to recur as a result of exposure in theworkplace. On the other hand, if the HCP consultedby the employer determines that the case is a chronicillness of the type addressed by paragraph1904.6(b)(1), the employer would not record the caseagain. In either case, the employer would evaluate itfor work-relatedness and then determine whether theoriginal entry requires updating or the case meetsthe recording criteria. Paragraph (b)(3) also recognizesthat the employer may ask for input from morethan one HCP, or the employer and employee mayeach do so, and in such cases, the rule requires theemployer to rely on the one judged by the employerto be most authoritative.§1904.6OSHA RECORDKEEPINGHANDBOOK43