Welcome to our monthly column featuring CONN-OSHA experts answering some of the most commonly asked questions from CBIA member companies.
Most of the responses from Catherine Zinsser, a CONN-OSHA occupational safety training specialist, will be on recordkeeping since that's the focus of most questions she fields.
But if you'd like to ask her a question on another topic, please email CBIA's Phillip Montgomery.
He will treat all questions confidentially and never share any identifying company information with CONN-OSHA or anyone else.
Q: Due to the repetitive nature of work, an employee showed symptoms of a muscle disorder—a sore wrist—in February, but lost no work time. Last month the soreness got to the point where he missed a day. Is this recordable the date of the diagnosis or the date of work loss?
A: OSHA's general recording criteria, specifically paragraph 1904.7(a), describe the basic requirement for recording an injury or illness in the OSHA recordkeeping system.
Employers must record any work-related injury or illness that meets one or more of these general recording criteria—death, days away from work, days of restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or diagnosis by a physician or other licensed healthcare professional as a significant injury or illness.
If the employee's soreness resulted in a diagnosis from a physician that met the basic recording requirement, the date of diagnosis would be used.
Q: Under what conditions can a company give more significance to a second physician's diagnosis as to whether to record an injury if it conflicts with the diagnosis of the first physician?
A: OSHA regulations found in paragraph 1904.7(b)(3) (ii) indicate the agency is aware there may be situations where the employer gets an opinion from a physician or other healthcare professional, and a second opinion differs from the first.
The second opinion could be from a healthcare professional retained by the employer or the employee.
In this case, the employer is the ultimate recordkeeping decision-maker and must resolve the differences in opinion.
The employer can make the recordability decision or turn to a third healthcare professional for this purpose.