The 300 Logs aren’t complex forms, but the nature of workplace injuries and illnesses, as well as treatment methods, are vast. Some events are easily recognized as recordable, others are not. The difference in a first aid injury and a recordable medical event is often a nuance, which means errors in 300 Logs are very common. Most pressing, the deadline for submitting your Log to OSHA looms.
By December 15, 2017, you must submit the 2016 300 Logs if you’re a covered employer, according to the Electronic Submission Rule, Most employers will likely fall under that Rule. (If you employ–or did employ– 20 or more workers in 2016, please review the submission criteria,) This means it’s time to clean up your documentation STAT!
(Note: This post has been updated to reflect the postponed deadline reflected by OSHA’s Final Rule page. The deadline had been December 01, 2017, but on November 27th, the agency moved the deadline for submission backwards to December 15, 2017.)
What is a Recordable Injury?
Recordable events are those which must be listed on your 300 Logs. But thankfully, not every workplace injury incident meets that requirement.
However, if you don’t know the difference between recordables and non-recordables, it can cause headaches and potentially costly violations.
Recordables on the 300 Log Include Work-Related:
- Injuries or illnesses that result in days away from work
- injuries or illnesses that result in restricted work or transfer to another job
- Medical treatment beyond first aid
- Loss of consciousness
- A significant injury as diagnosed by a healthcare provider (such as an electrical burn, etc.)
- Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
- There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.
- All amputations, losses of an eye, inpatient hospitalizations, fatalities.
Some Injuries are Recordable AND Reportable
And as January 1, 2015, under OSHA recordkeeping standards, incidents that must be recorded on 300 Logs AND reported to OSHA include:
- All work-related in-patient hospitalizations of one or more employees
- All work-related amputations
- All work-related losses of an eye
- All work-related fatalities
These work-related severe injuries must be reported directly to OSHA in an expedited time frame. That means–not only those recordable on the 300 Logs, they are also reportable injuries or illnesses.
You have 24 hours to send to OSHA reports of work-related in-patient hospitalizations of one or more employees, amputations and losses of an eye and 8 hours to report a work-related fatality. More about reportable injuries here.
Even if you employ only one worker and are otherwise exempt from other OSHA 300 Log recordkeeping, you still fall under the Severe Injury Reporting (SIR) Rule.
What Injuries are Non-Recordable?
Minor injuries that require only first aid are excluded from reporting on the 300 Log. They are non-recordable.
That brings us to our next question…
What is “First Aid” Under OSHA?
OSHA’s definition of first aid practices, may differ from your definition of “first aid,” so it’s important you and your workplace medical responders are aware of the distinction.
Below are “first aid” treatment which are non-recordable under the OSHA requirements:
- Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping 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, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
- Using hot or cold therapy;
- Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
- Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.).
- 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 (However, physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
- Drinking fluids for relief of heat stress.
Treating workplace illnesses or injuries using the above methods, whether by your Company response team or by a medical professional are typically considered non-recordable first aid events.
Pay Attention to Exceptions and Variations
In the chart below, you’ll see how just a few seemingly minor changes can alter the designation of a non-recordable first aid event to medical treatment (recordable).
Regulations Don’t Change Often, But Interpretations Do Frequently
I can’t stress enough how important it is for employers to keep current on OSHA’s regulations and OSHA’s Standard Interpretations. While it takes OSHA an average of 7-9 years to pass a single regulation, the agency can more easily adapt its interpretations on existing laws, which impact many areas– including 300 Logs and injury treatment.
For example, OSHA has two interpretations on medical/skin/wound glue. In 2002, the agency stated that if the glue products are used to “cover” a wound, like a bandage, this is first aid and non-recordable.
However, OSHA elaborated on this in 2004. If the glue is used to close a wound (not cover it as one would with a bandage) and the glue is a substitute for sutures or staples, the event is considered medical treatment and is therefore, recordable. If you use such a product at your workplace, you should review its use with first aid responders to ensure recordable events are not occurring without your knowledge.
An additional example, in 2014 OSHA classified use of Kinesiology tape as medical treatment, (and recordable) but upon reviewing data, OSHA reversed its earlier decision. In 2015, the agency determined that Kinesiology tape would be considered non-recordable, and would fall under first aid provisions.
Quickly brush up on the essentials of 300 Logs, with our post, “Back to the Basics: 300 Log 101,” which defines covered & partially exempt employers and discusses how to fill out forms accurately.
Employers should stay current on OSHA’s interpretations, upcoming laws and areas of focus by subscribing to the agency’s biweekly newsletter, OSHA’s QuickTakes.
And of course, follow our blog posts for relevant industry information on risk, safety, HR and emergency management.
Finally, here is a list of Standard Interpretations pertaining to 300 Logs, which you may find useful.