Provider helps employers define `recordable' injury

Information could be vital to your clients

Employers often have a hard time understanding what types of injuries and illnesses must be recorded, so it is useful to provide a list, says Karen Barrett, RN, COHN-S, an occupational health nurse with WorkMed, the occupational health program of Wilson N. Jones Hospital in Sherman, TX.

Barrett says well-meaning employers often are confused by the extensive regulations of the federal Occupational Safety and Health Administration and turn to her for advice. She considers it an important service of her program to explain the regulations simply and concisely, rather than just referring the client to the regulations themselves. Since she often is asked how to comply with OSHA requirements to keep records of workplace injuries and illnesses, Barrett and Lilly Ramphal-Naley, MD, MPH, the medical director at WorkMed, came up with a simple way to answer the question.

Savvy occupational medicine providers also should know that many managers will have safety bonuses tied to the number of OSHA-reportable incidents in their department. Thus having good definitions can have a direct impact on your clients.

First, define `medical treatment'

Barrett says she starts by explaining OSHA requires all employers with more than 10 employees in a calendar year to keep records of occupational injuries, illnesses, and deaths unless they are in certain industries defined as low-risk. But even for those that must keep records, OSHA limits the type of records that must be kept. For starters, the injury or illness must result in medical treatment, loss of consciousness, restriction of work or motion, or transfer to another job.

But first aid does not necessarily count as "medical treatment," Barrett explains. To make the event OSHA-recordable, the medical treatment must be provided by a physician or other licensed medical personnel. These other factors also will make the event OSHA recordable:

· The injury impairs bodily function, such as normal use of the senses or limbs.

· The injury results in damage to the body of a non-superficial nature, such as a fracture.

· There are complications that require follow-up medical treatment.

Lists help make distinctions

The WorkMed staff also explains that a visit to their clinic, or another facility, for an examination does not necessarily constitute medical treatment. If a worker goes to the clinic for X-rays for a possible broken bone, but the X-rays are negative, that would not constitute "medical treatment" just because he went to the clinic and had an X-ray taken. The rest of the visit would determine whether it met the criteria for medical treatment or just first aid; it is possible that the minor treatment provided in light of the negative X-ray would mean the visit was simply first aid.

To further help employers understand the distinctions, Ramphal-Naley and Barrett provide two lists to employers. One lists typical medical treatments that make an event OSHA recordable, while the other lists typical first-aid treatments that, by themselves, do not make an event OSHA recordable. They suggest occupational health providers may want to use the same sort of lists to help simplify the explanation to employers. WorkMed published the lists in its newsletter to clients.

This is the list of medical treatment that makes an event OSHA recordable:

n treatment of infection

n application of antiseptics during a second or subsequent visit to the health care provider

n treatment of second- or third-degree burns

n application of stitches

n application of butterfly or bandage strips instead of stitches

n removal of foreign bodies embedded in the eye

n removal of foreign bodies from a wound if the procedure is complicated because of the depth of the embedment, size, or location

n use of prescription medications (except for a single dose administered on the first visit for a minor injury or discomfort)

n use of hot or cold soaking therapy during a second or subsequent visit to medical personnel

n application of hot or cold compresses during a second or subsequent visit to medical personnel

n removing dead skin (surgical debridement)

n application of heat therapy during a second or subsequent visit to medical personnel

n use of whirlpool bath therapy during second or subsequent visit to medical personnel

n positive X-ray diagnosis for fractures

n admission to a hospital or equivalent medical facility for treatment.

This is the list WorkMed provides to explain what is considered only first aid, and therefore does not make the event OSHA-recordable:

n application of antiseptics during the first visit to medical personnel

n treatment of first-degree burns

n application of bandages during any visit to medical personnel

n use of elastic bandages during the first visit to medical personnel

n removal of foreign bodies from the eye if the foreign body is not embedded and only irrigation is required

n removal of foreign bodies from a wound, if the procedure is uncomplicated and simple

n use of non-prescription medications

n administration of a single dose of prescription medication on the first visit for minor injury or discomfort

n soaking therapy on the initial visit to medical personnel, or removal of bandages by soaking

n application of hot or cold compresses during the first visit to medical personnel

n application of ointments to abrasions to prevent drying or cracking

n application of heat therapy during the first visit to medical personnel

n use of whirlpool bath therapy during the first visit to medical personnel

n a negative X-ray diagnosis

n observation of the injury during any visit to medical personnel

n administration of a tetanus shot or booster, unless given in conjunction with more serious injuries that would constitute a recordable case.

Karen Barrett and Lilly Ramphal-Naley, WorkMed, 501 N. Highland, Suite 101, Sherman, TX 75092. Telephone: (902) 870-4530.