Getting it right: How to improve record keeping

Mistakes can lead to over- or underreporting

Underreporting injuries makes it more difficult to evaluate and correct hazards. But overreporting on the U.S. Occupational Safety and Health Administration (OSHA) log can inflate your incidence rate.

Meanwhile, mistakes in record keeping can lead to citations. Record keeping is one of the top 10 standards cited during OSHA inspections of hospitals. In fact, record keeping can be one of the most confusing aspects of occupational health.

"With record keeping, there are lots of gray areas," says Julie Nussbaum, senior workplace safety editor at J.J. Keller & Associates in Neenah, WI. "OSHA can lay down the basic requirements of what is recordable and what's not. But how many workplace incidents fit nicely into [a category]?"

OSHA audits the logs of 250 employers a year for quality assurance in record keeping. Two of the top issues that arise involve restricted work duty and work-relatedness of injuries, says OSHA economist Dave Schmidt. "We've concluded that about 90% are doing a good job and giving us good numbers," he says. "We do find errors. These are two of the big areas."

For example, suppose an employee has a back injury and can no longer lift more than 20 pounds. If the employer adjusts her job tasks so lifting is no longer required, the injury still must be reported on the log, says Schmidt. However, if lifting was never required in the job and the physician merely diagnosed her strain but didn't provide any prescription-strength medications or other treatment, then the incident would not be recordable.

"It has to affect the routine job functions the employee would be expected to do at least once a week," Schmidt says.

Similarly, various scenarios can bring questions about work-relatedness — for example, if the employee is off-duty but on hospital property. "There are so many scenarios out there; basically, there's always going to be some gray area," Schmidt says.

Distinguishing between first aid and medical treatment also is difficult for employers, says Nussbaum. When in doubt, many employee health professionals just go ahead and record an injury on the OSHA 300 log. If you do, don't worry that those injury rates will be used to determine which workplaces are "high incidence" and subject to targeted inspections. OSHA only looks at incidents that involve days away from work, job transfer or restricted duty, Schmidt says.

But while you want to monitor and address your injuries, you don't want to inflate your record keeping.

Nussbaum, who spoke at the spring conference of the Atlanta-based American Association of Occupational Health Nurses (AAOHN), and Schmidt shared record-keeping advice with Hospital Employee Health. We supplemented that information with background from OSHA letters of interpretation and its "Recordkeeping Handbook" published in 2005. (See editor's note for more information on obtaining help with record keeping.)

How do I determine if an injury is "first aid only"?

OSHA specifies a list of treatments that it considers to be "first aid." That includes using a bandage for wound covering, hot or cold packs for a sore muscle, or massage. If an employee gets treatment from a physical therapist or a chiropractor for work-related pain, that is a recordable injury, according to OSHA. (If the visit is only diagnostic or the treatment is only "first aid," such as suggesting exercises, then it is not recordable.)

So is taking nonprescription medicine at prescription-level strength. For example, a single-dose of naproxen sodium (such as Aleve) that is greater than 220 mg is prescription strength, OSHA says.

"If someone has a cut and you apply a prescription-strength antibiotic, that makes it recordable," notes Nussbaum.

Providing an immunization — other than tetanus — after an exposure would make an incident recordable, she notes.

What about needlesticks and other possible bloodborne pathogen exposures?

OSHA requires the reporting of all needlesticks and "cuts from sharp objects that are contaminated with another person's blood or other potentially infectious material." A needlestick with a clean needle is not recordable. A splash or spray of blood or body fluids is not recordable unless the employee takes prophylactic medications or develops an illness related to the exposure.

The OSHA 300 log can be used as the sharps injury log if "you enter the type and brand of the device causing the sharps injury on the log and you maintain your records in a way that segregates sharps injuries from other types of work-related injuries and illnesses, or allows sharps injuries to be easily separated," OSHA says.

Doesn't HIPAA restrict me from putting employee information on the log?

No. HIPAA doesn't apply to OSHA. However, OSHA outlines "privacy concern cases" in which an employer may not place the employee's name on the log. Instead, the employer must enter "privacy concern case" on the log and keep a separate list of the privacy concern case numbers and employee names. Privacy concern cases comprise: "an injury or illness to an intimate body part or the reproductive system; an injury or illness resulting from a sexual assault; mental illnesses; HIV infection, hepatitis, or tuberculosis; needlestick injuries and cuts from sharp objects that are contaminated with another person's blood or other potentially infectious material." An employee also may request privacy and ask for his or her name not to be entered on the log.

You must remove names from the log if you provide the log to someone other than government representatives, employees, former employees or their authorized representative (such as a union official), public health or law enforcement authorities, safety consultants, or for the processing of a workers' compensation or medical claim.

Do I record injuries of nonemployees, such as contract workers, medical students, or volunteers?

When contract workers are under your "day-to-day supervision," you are responsible for all OSHA injury and illness record keeping, according to OSHA. If students are paid, then there is an "employee-employer relationship" and record keeping is required. You don't have to record injuries and illnesses for unpaid workers.

How do you handle a nonwork-related injury, such as a back injury, that is aggravated by work?

You have to record a "significant aggravation" as a work-related injury if the employee suffers death, loss of consciousness, or one or more days away from work, restricted duty, or job transfer that wouldn't have occurred otherwise. Also, medical treatment that wasn't previously necessary or a change in medical treatment would make the incident recordable, OSHA says.

[Editor's note: The OSHA "Recordkeeping Handbook" is available at You can get answers to record keeping questions from your area or regional OSHA office or from OSHA's Office of Statistical Analysis. Contact Mark Kitzmiller, (202) 693-2291.]