Recording and Reporting a Serious Injury
On a Tuesday afternoon, a laborer on a commercial site falls from a 6-foot stepladder and fractures his wrist. He is taken to the emergency room, treated, and released the same day; the treating physician recommends he stay off work for 12 days and prescribes a splint but does not perform surgery or admit him. The site superintendent learns of the injury Wednesday morning. The company has 22 employees and is in an OSHA state-plan state that adopts federal recordkeeping rules. The superintendent says, "He wasn't hospitalized, so we don't have to report it, and we'll just note it in the log." No one has contacted OSHA. The company's OSHA 300 log has not been updated.
1. Does this injury trigger an OSHA reporting obligation to OSHA itself? Explain the reporting thresholds.
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Apply the federal reporting rules (adopted by the state plan): employers must report to OSHA within 8 hours any work-related fatality, and within 24 hours any work-related in-patient hospitalization, amputation, or loss of an eye. This injury involved an ER visit and release, not in-patient hospitalization, and no amputation or eye loss, so it does not trigger the 24-hour report to OSHA. The superintendent is right that hospitalization is the trigger for the 24-hour report, but wrong to conclude nothing else is required. The injury is still recordable on the OSHA 300 log because it is a work-related injury involving medical treatment beyond first aid and/or days away from work; the physician's 12-day restriction must be captured. Note also that the 8-hour fatality and 24-hour hospitalization clocks start when the employer learns of the event, so the Wednesday discovery date matters for any reportable event.
2. How should this injury be recorded, and what mistakes is the company making in its recordkeeping?
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The injury should be entered on the OSHA 300 log as a recordable case: it involved medical treatment beyond first aid (prescription and splint) and resulted in days away from work. The company must also complete the OSHA 301 incident report and post the OSHA 300A summary for the year. The 12 days off work should be recorded in the days-away column. Mistakes: the log was not updated; the superintendent is treating "no hospitalization" as "no recordkeeping," which conflates the reporting thresholds with the recording criteria; and no one is tracking the days away. The company should also check whether its state plan has additional or different requirements, since state plans can be stricter than federal rules. The superintendent should be retrained on the difference between reporting (8/24-hour calls to OSHA) and recording (300/301/300A).