CONN-OSHA Answers Your Safety Questions: October 2022

Welcome to our monthly column featuring CONN-OSHA experts answering some of the most commonly asked safety 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 is 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.

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Q: If we submit a workplace injury form to our WC carrier and the injury is denied as a workers’ compensation injury, do we still count that injury on our OSHA 300 log or do we disregard it?

When an injury or illness occurs to an employee, the employer must independently analyze the case in light of both the OSHA recording criteria and the requirements of the state workers’ compensation system to determine whether the case is recordable or compensable, or both.

Your case must be judged by the criteria of the OSHA recordkeeping rule to determine if it should be placed on the 300 log. 

Workers compensation is not a consideration of whether the case is OSHA recordable or not.

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Q: If an employee experienced a recordable hearing loss case, where would the employer record the case on the OSHA 300 log?

Prior to 2004, employers should record work-related hearing loss cases according to the instructions included with the recordkeeping forms. 

If the loss is associated with an event, such as acoustic trauma (e.g., an explosion), it would be recorded as an injury with a check mark in column (M)(1). 

If the loss is not an injury, it would be recorded as an illness, with a check mark in the all other illness column. 

Beginning in January 2004, employers must record all hearing loss cases in the separate hearing loss column (M)(5).

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Q: What is OSHA’s stand on an injury that occurs at work as a result of an employee being under the influence of illegal substances?

Being under the influence of an illegal substance is not a factor when determining recordability for OSHA recordkeeping purposes.

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For more information, contact CBIA’s Phillip Montgomery (860.244.1982).