Is It Recordable?Tendinitis Aggravation: is it recordable?
Question
A Shipping/Receiving employee has been tasked with opening and handling hundreds of boxes per day. After a full week of performing this task, he reports pain and swelling in his right elbow. An occupational health doctor evaluates the elbow and determines the employee is suffering from a flare-up of tendinitis, something the employee has struggled off and on with for a decade. The doctor opines the flare-up is from opening too many boxes and prescribes no use of the right arm for two weeks. The company cannot accommodate the work restriction and the employee is sent home for the next two weeks. Is it recordable?
Answer
YES. This should be recorded as a lost time incident. The doctor opined that the incident was work-related, and the employee received work restrictions that were not accommodated and became lost time. OSHA states that the work event or exposure need only be one of the discernible causes; it need not be the sole or predominant cause.
Letter of Interpretation The work event or exposure need only be one of the discernible causes; it need not be the sole or predominant cause.
How do I handle a case if it is not obvious whether the precipitating event or exposure occurred in the work environment or occurred away from work? In these situations, you must evaluate the employee's work duties and environment to decide whether or not one or more events or exposures in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing condition.
1904.5(b)(4) How do I know if an event or exposure in the work environment "significantly aggravated" a preexisting injury or illness? A preexisting injury or illness has been significantly aggravated, for purposes of OSHA injury and illness recordkeeping, when an event or exposure in the work environment results in any of the following:
1904.5(b)(4)(i) Death, provided that the preexisting injury or illness would likely not have resulted in death but for the occupational event or exposure.
1904.5(b)(4)(ii) Loss of consciousness, provided that the preexisting injury or illness would likely not have resulted in loss of consciousness but for the occupational event or exposure.
1904.5(b)(4)(iii) One or more days away from work, or days of restricted work, or days of job transfer that otherwise would not have occurred but for the occupational event or exposure.
1904.5(b)(4)(iv) Medical treatment in a case where no medical treatment was needed for the injury or illness before the workplace event or exposure, or a change in medical treatment was necessitated by the workplace event or exposure.
1904.7(a) Basic requirement. You must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. You must also consider a case to meet the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
https://www.osha.gov/laws-regs/standardinterpretations/2004-01-13
https://www.osha.gov/laws-regs/interlinking/standards/1904.5(b)(4)
https://www.osha.gov/laws-regs/interlinking/standards/1904.7(a)
