Are All Chemical Exposures Recordable Injuries?
In her letter to OSHA, the writer requests clarification about a specific 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?
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:
Latest OSHA Rules for Injury and Illness Reporting
- Is work-related,
- Is a new case, and
- 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.
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?
Is the Incident Above a Recordable 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.
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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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