By Brian Zaidman, Research Analyst, Research and Statistics, Minnesota Department of Labor & Industry Reprinted from "Safety Lines: The Newsletter of Minnesota OSHA," April 2009.
Editor's note: This is the fouth installment of an occasional series of more advanced topics about recording occupational injuries and illnesses using the OSHA Form 300. This information is directed to people who are new to OSHA recordkeeping activities, who want to review their recordkeeping practices or who want to improve their recordkeeping skills. The previous series about
recordkeeping, covering basic information about filling in the OSHA log and creating an annual summary is available at www.minnesotasafetycouncil.org/MO/articles.cfm.
Recording a work-related injury or illness as an "other recordable case" requires more judgment and
knowledge of the OSHA recordkeeping requirements and more monitoring of the health care treatment
provided to the injured worker than does coding any other type of case. The OSHA log is a tool for
recording and counting work-related injuries and illnesses that reach the level of severity where the
affected worker misses time from work, is unable to perform his or her regular work duties or requires
medical treatment. Not all work-related injuries will rise to this level of severity.
In its simplest definition, an other recordable case is a work-related injury or illness that does not involve death, one or more days away from work, or one or more days of restricted work or job trasfer, and where the employee receives medical treatment beyond first aid. Remember that days away from work, days of restricted work and days of job transfer begin after the day the injury occurred or the illness began.
Thus, if the injured worker does not receive medical treatment (as defi ned below) but misses a day of
work, the case is recorded as a days-away-from-work case. If the injured worker does not receive
medical treatment and does not lose any time from work, the case is not recordable.
Work-related injuries and illnesses that do not meet the standard for being counted as recordable cases should be removed from the OSHA log to ensure they are not mistakenly included in the incident rate calculations. This does not mean these injuries and illnesses should be ignored; they are often indicative of hazards and conditions that could lead to more severe injuries and illnesses and should be investigated, with hazards mitigated. The definitions of medical treatment and first aid are vital to understanding which injuries and illnesses are other recordable cases and which are not recordable cases. This installment will focus on the definition of medical care; the next installment will focus on first aid. If you wish to read ahead, see the OSHA recordkeeping requirements at 1904.7(b)(i).
What is a medical treatment?
Medical treatment is defined in the recordkeeping requirements at 1904.7(b)(i).
Medical treatment means the management and care of a patient to combat disease or
disorder. Visits to a health care professional or a hospital for observation, testing,
diagnosis or to evaluate diagnostic decisions are excluded from the definition of
medical treatment. Diagnostic procedures are used to determine whether an injury or
illness exists, and do not involve the therapeutic treatment of the patient.
Counseling is excluded from the definition of medical treatment, regardless of whether the
counselor is a licensed health care professional or an unlicensed person with limited training.
Prescription medications are powerful substances that can only be prescribed by a
licensed health care professional. The issuance of a prescription is regarded as medical
treatment, regardless of whether any medication was actually taken by the patient.
Cases in which the injured or ill worker is given a prescription from a health care
professional need to be coded, whether the prescription is filled or taken. The worker’s
acceptance or refusal of the treatment does not alter the fact that a health care
professional judges treatment is necessary. This includes cases where a health care
professional tells a patient to take prescription pain medication only if pain relief is
needed, and no pills were taken.
Prescriptions for medications available over-the-counter are not considered medical
treatment if they are used at nonprescription strength. However, if a drug available in
both prescription and nonprescription strengths, such as ibuprofen, is used or
recommended for use by a licensed health care professional at prescription strength,
then the criterion for medical treatment is met and the case must be recorded.
The use of orthopedic devices, such as splints or casts, is considered medical
treatment. These devices are typically prescribed by licensed health care professionals
for long-term use and are typically used for serious injuries and illnesses. However,
orthopedic devices used only during an emergency to stabilize an accident victim
during transport to a medical facility are not considered medical treatment.
Because physical therapy and chiropractic manipulation are treatments used for more
serious injuries and are provided by licensed personnel with advanced training, they
are considered medical treatment beyond fi rst aid. If a chiropractor provides
observation, counseling, diagnostic procedures or first aid procedures for a work-related
injury or illness, the case would not be recordable.
Federal OSHA recordkeeping resources
MNOSHA recordkeeping resources
MNOSHA WSC recordkeeping training
Survey of Occupational Injuries and Illnesses
Packet of recordkeeping forms, instructions
Booklet: Minnesota OSHA recordkeeping requirement