New Year’s gift: Rule offers record-keeping relief

EHPs laud OSHA’s new standard

Here’s a rare event: Employee health professionals (EHPs) are looking forward to the start of new regulations. On Jan. 1, new record-keeping rules and forms will go into effect that will clarify the reporting of injuries and illnesses. The U.S. Occupational Safety and Health Administration (OSHA) actually is being lauded for an easy-to-read standard that includes numerous examples and definitions.

"The original regulations were confusing. For many, many years, we had heard there would be improvements made," explains Annette Haag, MA, RN, COHN-S/CM, FAAOHN, an occupational health and safety consultant in Simi Valley, CA. "The best improvement made on this particular standard was the new format [OSHA] decided to use — a user-friendly format," she adds.

When is an injury considered first aid only, which means reporting is not required? How do you count lost workdays? When do you stop counting lost workdays? All of those questions clearly are answered by OSHA. And the answers, in many cases, differ from those in the old standard.

For example, OSHA has been very specific in defining first aid, notes Sandy Winzeler, MN, MPH, ANP, COHN-S, employee health nurse practitioner at Emory Hospitals in Atlanta. (For more help on the rule, see "OSHA record-keeping resources" in this issue.) "[First aid] encompasses so much more than it used to. Some of the things that we used to record by law now are not considered recordable."

Meanwhile, OSHA has delayed the implementation of two controversial provisions until Jan. 3, 2003. For the year 2002, employers won’t need to designate musculoskeletal disorders (MSD) in a separate column on the OSHA 300 log. Those injuries will continue to be recorded the same way as in the past. OSHA also delayed and will reconsider the rule’s definition of MSDs.

OSHA also postponed the new record-keeping provision on hearing loss. The record-keeping rule would have set the standard threshold shift of hearing acuity at an average of 10 decibels when measured at 2,000, 3,000, and 4,000 hertz in one or both ears. For the next year, OSHA has instructed employers to record work-related shifts in hearing of an average of 25 decibels or more at 2,000, 3,000, and 4,000 hertz in either ear.

While the new rule will make record keeping easier in many ways, hospitals will likely report a higher number of injuries and illnesses. All needlesticks involving contaminated sharps are recordable, even if they don’t require prophylaxis or vaccination. The OSHA 300 log can be used as the needlestick log required by OSHA’s revised bloodborne pathogen standard, as long as it contains complete information on the device, brand, and incident. But many EHPs say they plan to continue to maintain a separate needlestick log, in addition to a briefer notation on the OSHA 300. "In a hospital [setting], where you have quite a few bloodborne pathogen exposures, I think it would be helpful to keep a separate log," says Winzeler.

Meanwhile, EHPs will make new determinations of what belongs on the OSHA 300. As an example of how record keeping will change, Winzeler cites the case of an employee with a minor laceration. If you used a Steri-Strip to keep the wound edges closed, under the old standard the injury would have been recorded. Now, OSHA says that’s not necessary unless the wound requires stitches or antibiotics. "You get down to the whole reason why we’re tracking these injuries to begin with," she says. "We’re really not interested in the really minor things. We’re trying to track and trend significant injuries and illnesses."

If an employee sustains a bruise and an employee health nurse recommends soothing it with ice, that minor injury would not be recordable. But advice for repeated use of ice would have made it recordable under the old standard, says Winzeler, who is an instructor for the record-keeping seminars offered by the American Association of Occupational Health Nurses in Atlanta.

OSHA isn’t tracking "lost workdays" anymore. But the agency has defined "days away from work" and "restricted work" days due to injury to include any recuperation time — even if those days fall during a weekend, vacation, or other off-duty time. Here’s an example of how that will change the recording of injuries: A nurse strains her back as she helps a patient transfer from a bed to a chair. An employee health nurse or physicians advises her to use cold packs and over-the-counter anti-inflammatories. The injury happens on a Friday, and she isn’t due back to work until Monday.

Under the old standard, the repeated use of cold packs would make the injury recordable. However, the two days of recuperation would not entail lost workdays. With the new standard, the cold packs and anti-inflammatories would be considered first aid. But if a licensed health care professional advised the employee that she needed two days to recuperate — that she couldn’t perform her usual duties for those two days — then the injury would be recorded with two days of lost time.

"If you know that person really should be off those two days to get better, or if you feel they could be [at work] but be restricted from lifting and bending, it should be reflected like that," says Winzeler. "It’s really incumbent on physicians to be very clear as to whether the person actually could have worked or not. If they could have worked, [they need to note] whether they could have done their routine functions or not." The agency capped the number of days away from work or restricted days at 180. After that, no further tracking is necessary. At the end of the year, the EHP may estimate the days away or restricted days related to any existing injuries and close the log.

The determinations about what’s recordable have been extended to illnesses, as well. OSHA now doesn’t distinguish between injuries and illnesses in the recording rules, notes Haag. "Before you had to decide whether an injury required first aid only or medical treatment. You did not have to record first aid injuries," she explains. "But you had to record all diagnosable illnesses. Now you treat an illness the same way you would treat an injury. You have to decide if that illness is significant," Haag says. Illnesses would include dermatitis and work-related asthma.

The OSHA 300 also includes special recording criteria for occupational transmission of tuberculosis. If an employee is exposed to someone with a known case of tuberculosis and later has a positive skin test or a diagnosis of TB, you must check a box labeled "respiratory condition." If further investigation shows that the TB exposure occurred outside the workplace — such as from an infected family member or acquaintance — the record can be deleted, the OSHA standard says.

Until hospitals have several years of experience with new forms and new definitions, it will be difficult to track trends in injuries and illnesses. The tally on the OSHA 300 log can’t be compared directly with previous OSHA 200 records. "We’re going to have to have this log in place for a few years before we can really compare apples to apples," says Winzeler. But she notes that EHPs still can look at important indicators, such as cost per case. Ultimately, the new log will provide valuable information, she says. It’s information that top administrators also must acknowledge. The new rule requires a company executive to certify that the log is accurate and complete. "By signing it, they’re saying they have reviewed it, they understand it, and they realize what their lost and restricted days [are in total]," says Winzeler.

[Editor’s note: OSHA will offer a satellite broadcast and simultaneous live webcast on Nov. 29 from 1 p.m. to 3 p.m. For information, see the web site: keeping/index.html. The American Association of Occupational Health Nurses in Atlanta offers occasional workshops on record keeping. See their web site at or call (770) 455-7757.]