For example, give the injured employee over-the-counter medication in an over-the-counter dose instead of prescription medication if medically appropriate.
For small cuts, use butterfly bandages when medically appropriate rather than sutures or dermal adhesive.
For chemical inhalation, don't give the employee oxygen unless it's medically necessary.
For sore arms, provide a support device for the arm rather than immobilize the arm.
For minor heat stress, limit the treatment to drinking fluids and avoid an IV administration of fluids.
There should be no intent to circumvent treatment that is necessary. But good management of treatments can avoid recordables.
When feasible, make the doctors and nurses at the off-site private clinic that you use aware of the rules, too, so that they do not over treat one of your employees who has been injured or made ill on the job.
If feasible, educate local hospital emergency room doctors where you send your employees when on-site medical personnel aren't available about recordable versus non-recordable treatments.
For example, if your employee is told to take the next day off by an emergency room doctor because of a work-related injury, your more authoritative physician who knows the job responsibilities and the tasks required better than the emergency room doctor may instruct that employee to continue working, but with restrictions from routine duties.
The more authoritative physician is normally your company doctor, a board-certified occupational physician or specialist. In the above scenario, you have avoided a day away from work case, and can record this case as restricted duty.
Your more authoritative physician may instruct the injured employee to continue all routine duties, but at a slower pace. A slowdown in production, by itself, does not make the case OSHA recordable. If this happens, you have avoided both a day away from work case and a restricted duty case.
If the employee hurts his back one evening in the city bowling league, comes to work the next day, doesn't tell anyone his back hurts and the job significantly aggravates his bad back, you've got yourself an OSHA recordable. But if you know about the bad back before the employee starts work, you could put him on light duty or not let him return to tasks that may aggravate the hurting back until it has healed up.
You've avoided a recordable, and even better, you've helped the employee by giving his back a chance to heal.
Consider having employees report all off-the-job injuries that require medical treatment, or a doctor's visit, or illnesses that result in at least one day of bed rest.
For example, your employee hurts his back one day at work, but it's not bad so he chooses to keep working and not tell anyone. That evening while at home, the back feels worse, so the employee goes to the local immediate care clinic to have it examined. The doctor at the clinic prescribes a pain medication. The prescription makes this case OSHA recordable, even if the employee chooses not to fill the prescription.
If your employee had been instructed to report the injury immediately at work when he felt the pain, or to contact a company doctor from his home that evening, over-the-counter medication and rest for the remainder of the day may have been medically appropriate. If that was the end of the treatment, a recordable could have been avoided.
But there must not be any medical treatment given or needed; there can be no loss of consciousness; no bone or tooth was broken, cracked or chipped; and no contaminated sharps injury was involved. And the injury or illness must not be one of the significant injuries and illnesses that are always recordable.
Remember, it's not the next scheduled work shift any more, it's the next calendar day because under the new rules, we must count calendar days for days away from work and restricted duty.
We can use that day of the injury to let the employee heal and recuperate by sending him/her home for rest or providing light duty for the rest of the shift. This time may be enough to allow the employee to recuperate and you have avoided a potential OSHA recordable.
No, because OSHA standard 1904.7(b)(3)(iii) states that recordability is not based on what the employee does, but what the doctor says he can do. All that is necessary is to document in the medical record that the doctor's opinion was that the employee was capable of working full duties.
Ensure that your job descriptions are current in describing all routine duties so that you can make decisions quickly about what may be restricted duty and what may not be restricted duty.
Recreational activities are those activities that you sanction, such as the use of a walking trail on company property, or maybe you let employees play basketball during their breaks at a net set up in an area of the warehouse. Injuries and illnesses that occur during these activities are not OSHA recordable.
Horseplay would be activities that you prohibit or should prohibit, such as trying to squirt a co-worker with a fire extinguisher, or throwing sharp objects while at work. Injuries and illnesses that occur during these activities are work-related and may be recordable if the recordability criteria (medical treatment, loss of consciousness, etc.) apply.