Keeping Records When One of Your Employees Gets a Cut

Issue: You are the HR manager for a publishing company, and one of your duties is ensuring compliance with the injury and illness recordkeeping requirements of the Occupational Safety and Health Administration (OSHA). In the course of a week, one of your employees suffered a mild scissors cut that required a bandage, while a second employee suffered a more serious laceration from a paper cutter. The latter employee’s wound was closed using butterfly adhesive dressings. Are both incidents of medical treatment recordable for OSHA recordkeeping purposes?

Answer: No, only the paper cutter laceration. In 1971, OSHA issued a regulation, Recording and Reporting Occupational Injuries and Illnesses, which states that occupational injuries involving medical treatment must be recorded on the OSHA No. 200—Log and Summary of Occupational Injuries and Illnesses.

In 1986, OSHA published the Recordkeeping Guidelines for Occupational Injuries and Illnesses to provide employers with supplemental instructions to the recordkeeping forms. OSHA provides the following guidance for distinguishing between medical treatment and first aid:

Medical treatment.
The following are generally considered medical treatment. Work-related injuries for which this type of treatment was provided or should have been provided are almost always recordable …

• Application of SUTURES (stitches)

• Application of BUTTERFLY ADHESIVE DRESSING(S) or STERI STRIP(S) in lieu of sutures….

First aid.
The following are generally considered first aid treatment (e.g., one-time treatment and subsequent observation of minor injuries) and should not be recorded if the work-related injury does not involve loss of consciousness, restriction of work or motion, or transfer to another job:

• Application of BANDAGE(S) during any visit to medical personnel.

Wound closure vs. wound covering.
The underlying distinction in these types of treatment is between wound closures and wound coverings. Sutures (stitches), Steri Strips™, staples, butterfly adhesive dressings, etc., are all classified as wound closures, which are intended to align the edges of wounds and to promote healing. On the other hand, bandages (Band-Aids™, gauze pads, etc.) are wound coverings, which are intended to prevent the invasion of bacteria and infection to an open wound.

The application of a wound closure is considered medical treatment for OSHA recordkeeping purposes, while the use of a wound covering is deemed to be first aid treatment.

Therefore, in the scenario above, a mild scissors cut that is dressed with a bandage would be considered first aid treatment and not recorded for OSHA injury and illness recordkeeping purposes.

However, the use of topical skin adhesives to close a wound, such as a serious laceration from a paper cutter, would be considered medical treatment for OSHA purposes. A work-related laceration that receives this type of medical treatment would have to be recorded on the OSHA Log 200.

CITE: 29 CFR Part 1904—Recording and Reporting Occupational Injuries and Illnesses; Recordkeeping Guidelines for Occupational Injuries and Illnesses, pp 42-43.

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