Are All Chemical Exposures Recordable Injuries?

Posted on 11/22/2017 by Roger Marks

In an interpretation letter dated September 14, 2017, the Occupational Safety and Health Administration (OSHA) answered a safety professional’s question about recording workplace injuries and illness related to chemical exposure.

In her letter to OSHA, the writer requests clarification about a specifiSmall_Chemical_Spill_2_1572648.jpgc chemical exposure incident that occurred at her workplace.

An acid line ruptured, exposing three employees to 15% hydrofluoric acid. After the exposure occurred, the employees underwent an off-site medical evaluation. Two of the three employees complained of difficulty breathing and other symptoms. Doctors who evaluated the employees stated that they did not exhibit any symptoms and released the workers back to full duty after administering first aid only.

Related Reading: Fainting at the Sight of Blood—Is It Recordable?

Latest OSHA Rules for Injury and Illness Reporting

Employers in non-exempt industries with ten or more full-time-equivalent employees (including temporary workers and contractors) must record each fatality, injury, or illness that:
  1. Is work-related,
  2. Is a new case, and
  3. Results in death; days away from work, on restricted work, or transferred from usual work (DART); medical treatment beyond first aid, loss of consciousness; or a "significant injury or illness" as diagnosed by medical professional.
In 2016, OSHA finalized a rule to require employers to make annual, electronic reports of injury and illness data from OSHA Forms 300, 300A, and/or 301. Earlier this year, OSHA delayed the deadline for employers to submit electronic reports of 2016 injury and illness data until December 1, 2017.

Is the Incident Above a Recordable Injury?

So, if an employee is exposed to a hazardous chemical and complains of symptoms (shortness of breath, skin irritation, congestion, etc.), is the company always required to record the incident as a workplace injury?

OSHA says no. In this case, because the employees underwent medical evaluation that determined they exhibited no symptoms, no recordable injury occurred in OSHA’s view. 

The Agency goes on, “In determining whether a case is recordable, the employer must first decide whether an injury or illness, as defined by the rules, has occurred.” 

But don’t be mistaken—a lack of visible or apparent signs or symptoms does not, by itself, exempt the employer from recording the illness. If an employer is unsure whether an injury or illness has occurred, the employer may rely on a healthcare professional’s opinion or diagnosis to determine if the event must be recorded.

Convenient, Reliable OSHA Safety Training     

Available 24/7, Lion’s interactive OSHA safety training courses are designed to satsify OSHA's 29 CFR safety standards and empower workers to identify, mitigate, and avoid the hazards in your workplace.

Employees who complete OSHA training at are ready to make on-the-job decisions that keep themselves and their co-workers safe. Our 10 Hour OSHA General Industry course focuses on hazard identification, avoidance, and control and prevention measures and includes several modules on electrical safety.

New HAZWOPER Awareness Online Training Now Available

Red-Button-Blog.jpgLion Technology this week launched a new HAZWOPER Awareness level training for employees at industrial facilities who may discover or witness a hazardous substance emergency release.

OSHA requires initial and annual refresher training for personnel responsible for initiating emergency response by alerting the proper authorities or sounding alarms. The new HAZWOPER online course—OSH 308—is designed to satisfy the classroom-based competency training required by 29 CFR 1910.120(q)(6).

This interactive, 2-hour online course is designed to satisfy either the initial or annual refresher training requirement for HAZWOPER awareness-level personnel.

Tags: osha, OSHA training, reporting and recordkeeping, safety, safety training

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