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OSHA's interpretation of what is reportable has gone to the extreme

January 28, 2010
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Your concern regarding the underreporting of accidents and injuries is a concern. You have a valid point. However, there are compounding issues related to this underreporting, one of which is OSHA’s interpretation of what is reportable has gone to extreme.

A women during her break knitting jammed the knitting needle into her hand. OSHA ruled this injury is OSHA reportable since it happened at work. Workers compensation would deny the injury since it was not related to the employee’s work and accomplished during her break. It has gotten to the point that if an employee clocked out, and hurt himself in the parking lot, it would be OSHA recordable. Workers’ compensation would deny the claim. OSHA has caused some of the confusion.

If an employee was injured at work, went to the clinic and the clinic indicated that this was a first aid case, this is not OSHA recordable. I have no doubt that if that employee took the rest of the day off, say a Friday, and reported to work Monday, this would be OSHA recordable, since there was lost time.

The employer is penalized for underreporting injuries and illnesses. What would happen to the system if the employer reported everything? (even the very minor first aid cases). I have no doubt that OSHA would have some penalty structure developed for that occurrence.
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OSHA Injury Reporting

Ralph Blessing
February 1, 2010
The whole process has become a quagmire of bureaucracy. There needs to be a new focus on this issue. Many safety professionals are under the gun to keep statistics "reasonable" and look at ways to get around a recordable. The use of butterfly band-aid comes to mind. It is a form of holding together the wound to allow it to heal. What is the difference versus the traditional sutures? A needle and thread?

OSHA Injury Reporting

Ken Waegerle
February 4, 2010
As safety professionals we find ourselves at times straddling between recording and non-recording of incidents. I have found it easier to conduct my investigation, interview the employee(s) and if it is not clear cut, I simply call our OSHA Consultative serviices and they assist in rendering a position or interpretation. In North Carolina they are very helpful and it adds to our record credibility. Fill out the form 301, document the conversation and the reasoning behind the decision. When in doubt, record it!

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