What kinds of incidents need to be counted as recordable incidents on the OSHA 300 log? Whole seminars have been devoted to that question. When veteran safety guys get together, chances are good the topic of recordables is likely to come up. Now a new OSHA letter of interpretation adds a slightly bizarre wrinkle to the issue. In a letter that was placed on the OSHA website lasts month, the agency says that, if a worker has a minor cut and faints at the site of his own blood, the company must record the injury. In the particular scenario, the worker has a small cut on his finger and puts a band-aid on it. OSHA says that would not have been a recordable. However, the worker then sees the blood and faints. OSHA says that, even though the cut is not recordable, the worker lost consciousness because of a work-related incident and that is a recordable.
It all seems pretty ridiculous and it lends itself to the view of many in industry that OSHA’s has an arbitrary and anti-business bias when it comes to recordables. On OSHA’s side, the agency has been handed the impossible task of trying to be specific about a very vague requirement. The OSH Act is where the reporting requirement comes from and this is the only thing it says about reporting incidents:
The Secretary, in cooperation with the Secretary of Health and Human Services, shall prescribe regulations requiring employers to maintain accurate records of, and to make periodic reports on, work-related deaths, injuries and illnesses other than minor injuries requiring only first aid treatment and which do not involve medical treatment, loss of consciousness, restriction of work or motion, or transfer to another job.
So OSHA doesn’t have a lot of direction from Congress about how it should rule on these very uncommon occurrences. But rulings like this certainly don’t make America’s workplaces any safer; they just tend to skew the numbers in ways that can make us miss more serious statistical indicators. and leaves industry wondering, “What is next? Mandatory training on smelling salts?”