Is injury recordable? Take a strong stance, or risk OSHA violations

Pressure may be strong to under-report

Editor's Note: This is a two-part series on occupational health's role in preventing recordkeeping violations. This month, we cover strategies to identify and prevent violations, and what OSHA's new enforcement emphasis means for your workplace. Next month, we'll report on common recordkeeping violations being found in workplaces.

An employee who was injured because of a safety rule violation may not want management to know that an injury occurred because of the possible consequences. On the other hand, if management takes great pride in a low injury rate, supervisors might have a lot of explaining to do for a recordable injury.

Either way, an injury that is not recorded appropriately risks a recordkeeping violation from the Occupational Safety and Health Administration (OSHA).

"Recordkeeping is a huge problem," says Michelle L. McCarthy, RN, COHN, on-site medical case manager for Genex Services in Norcross, GA. "Many places don't realize just how much detail is required for OSHA."

Thomas Slavin, safety and health director at Navistar International, a Warrenville, IL-based manufacturer of trucks and diesel engines, says, "These days, OSHA is really looking at recordkeeping issues. Knowing what the rules and nuances are, is really critical."

Push back

A strong stance may be needed to resist pressure from others who want you to make changes in recordkeeping. "Pressure can come from many directions," says Slavin. "Know the rules and don't fall to the temptation to make changes."

Some workplaces have incentives for reaching certain injury-free milestones, such as one million hours without a recordable injury. It's easy to see why everyone will want the treatment to be recorded as First Aid only.

"There are people who don't want a case to be recordable, or a prescription to be given," says Slavin. "The important thing is, do the right thing for the injury. Remember that you are the professional, if you will, and should push back at times."

The facts and good medical judgment are your best allies. "Understand that people may be disappointed. Some may try to blame the messenger, but recording is not an option," says Slavin. "Good medical practice dictates proper treatment, and regulations dictate what is recordable. "

One challenge is that many times, OSHA numbers are the easiest performance indicators available. Part of a supervisor's or manager's evaluation may be based on those numbers.

The problem is that most companies use OSHA recordkeeping statistics, on the number of recordable incidents or lost time cases, as a way to measure performance, says Patricia B. Strasser, PhD, RN, COHN-S/CM, FAAOHN, principal of Partners in BusinessHealth Solutions in Toledo, OH.

"Managers, including senior managers, may have their financial bonuses impacted by the OSHA injury rates," she explains. "This drives the pressure to keep cases from being recordable, or to keep an injury from being a lost time case."

While many people use the OSHA injury numbers for performance measurement, they are really intended for statistical control, notes Slavin. "It's hard for people to understand that a particular case was recordable, even though management was not at fault and could not have foreseen or prevented the injury," he says.

If someone injures themselves with a knitting needle while on lunch break in the company cafeteria, the case may be recordable but may not really indicate a defect in the safety program.

"It is much better to use 'leading' performance indicators instead of 'trailing' or after-the-fact performance indicators, such as injury rates," says Slavin. "Supervisors cannot do much to control trailing indicators, but they can control leading indicators." These may be audit scores, the percentage of people trained or tested, employee survey results, the reduction in the number of noisy machines, or other activity-based metrics. "When someone complains about a recordability decision, you could take the opportunity to suggest a better set of performance metrics," advises Slavin.

Step into role

An occupational health nurse or physician may have total responsibility for OSHA recordkeeping, or be responsible for providing information to the person who is in charge of this area. "In either case, it is vital that the occupational health professional is knowledgeable about recordkeeping requirements," says Strasser.

McCarthy recommends offering to assist safety or human resources with monitoring the OSHA log. "This is a great way to help out," she says.

An occupational health nurse or physician will have treated an employee for occupational illness or injury, and should have access to the initial and on-going medical information if care is delivered by an external provider.

"The medical information is the basis for determining whether a case meets recording criteria or not, such as restricted work activity, medical treatment beyond First Aid, or loss of consciousness," says Strasser.

As you continue to monitor the employee's care, be aware of any changes that signal a need to update the OSHA log. "A case may initially be 'medical treatment only,' but later result in the need for work limitations or days away from work," says Strasser.


For more information on preventing recordkeeping violations, contact:

• Michelle L. McCarthy, RN, COHN, On-Site Medical Case Manager, Genex Services, Norcross, GA. Phone: (770) 266-4922. Fax: (770) 266-4869. E-mail:

• Thomas Slavin, Safety and Health Director, Navistar International, Warrenville, IL. Phone: (312) 836-3929. E-mail:

• Patricia B. Strasser, PhD, RN, COHN-S/CM, FAAOHN, Partners in BusinessHealth Solutions, Toledo, OH. Phone: (419) 882-0342. Fax: (419) 843-2623. E-mail: