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Copyright 2023 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
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RegSenseInjury and Illness Recording CriteriaOSHA RecordkeepingBest ResultsFAQUSAEnglishFocus AreaInjury and Illness Recordkeeping
If an employee has an injury or illness that is not recordable, but later becomes recordable, when do I record it?
If you can identify a single event or exposure that caused the injury (such as a trip or fall), record the case using that date even if the injury was not recordable until a later date. For example:
- An employee falls and cuts his hand, but does not require medical treatment or otherwise meet the recording criteria. Several weeks later, the cut has become infected and requires a prescription anti-biotic. The case would be recorded using the date of the fall because the precipitating event can be identified.
If you can not identify a single event or exposure, the injury is recorded on the date it becomes recordable, or on the date it is diagnosed by a physician or other licensed health care professional. For example:
- An employee complains of wrist pain, and her workstation is given an ergonomic evaluation to alleviate the condition. Three weeks later, the employee visits a physician and is diagnosed with carpal-tunnel syndrome. She is given physical therapy and placed on restricted duty. The injury would be recorded on the date of diagnosis by the physician, since the injury did not meet the recording criteria before that time and because you can not identify a single date or incident that caused the condition.
- If the initial complaint had involved discomfort that required a restriction in work duties, then the injury would have been recordable on the date of the complaint because it met the general recording criteria (restricted duty).
The concept of recording on the date of diagnosis comes from 1904.7(b)(7), which requires recording significant cases (such as cancer) on the date of diagnosis because no specific date of onset can be determined. This concept has been extended to other cases where a specific event or incident can not be identified. If you can identify an event or incident that caused the injury, record the case using that date.
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