Is It Recordable?
Scenario Q127

Ergonomic Deficiency: is it recordable?

Verdict: Recordable
Published 2021-01-31

Question

An office worker develops tendonitis in his wrist and is provided medical treatment and work restrictions, resulting in a recordable injury. The tendonitis resulted from poor ergonomics. The employee recovered completely from the tendonitis. 10 months later, the same employee sees a doctor, receives surgery and misses several days of work due to tendonitis in his same wrist. Is it recordable?

Answer

YES. Ergonomic and cumulative trauma injuries are not excepted in the recordkeeping language and therefore should be recorded if they result in medical treatment beyond first aid, work restrictions or days away from work. The second occurrence of tendonitis should be considered a new case and the surgery received makes it a second recordable even though it is for the same employee and the same body part.

1904.5(a): Basic requirement. You must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception in §1904.5(b)(2) specifically applies

Letter of Interpretation:

1904.6(a): Basic requirement You must consider an injury or illness to be a "new case" if:

1904.6(a)(1): The employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body, or

1904.6(a)(2): The employee previously experienced a recorded injury or illness of the same type that affected the same part of the body but had recovered completely (all signs and symptoms had disappeared) from the previous injury or illness and an event or exposure in the work environment caused the signs or symptoms to reappear.

Illustration for the scenario: Ergonomic Deficiency

#RedBeard #osha #osharecordkeeping #safety #workerscomp #occupationalsafety #recordkeeping #injuries #HR #injury #ergonomics #cumulativetrauma #tendonitis



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This is guidance based on 29 CFR Part 1904 and OSHA letters of interpretation. Facts and details may be altered or fictional. As specified by OSHA, the employer is responsible for the final recordability determination.