OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
February 19, 1997
Kem McVey Honeywell, Inc.
Houston, Texas 77063
Dear Mr. McVey:
Thank you for your letter dated January 3, requesting interpretations regarding several OSHA injury and illness recordkeeping issues. Whenever possible, I will refer to the Recordkeeping Guidelines of Occupational Injuries and Illnesses by stating the appropriate page and Q&A numbers.
Q1. An employee is copying documents when the copier jams. Upon removing papers from the machine's internal workings, the employee's ring finger contacts the hot drum. First aid is immediately administered at the site and the injury is classed as a first-aid case because only redness is present at the time of treatment. The following day, the finger is re-examined and no changes to the wound's appearance is detected. However, on the third day a bliser has formed where the burn occurred but no treatment is performed. The blister is left to heal and disappears within the next few days. Is the wound to be upgraded to a second degree burn?
A1. Yes. A second degree burn is characterized by blistering as well as reddening of the skin, edema, and destruction of the superficial underlying tissues.
Q2. Is it to be recorded on our OSHA 200 log as a second degree burn although no treatment was given?
A2. Any work related second degree burn that is larger than a pinhead or any work related third degree burn (regardless of size) is considered a non-minor injury for recordkeeping purposes. As found on page 42 of the Guidelines, a non-minor injury is one that results in damage to the physical structure of a non-superficial nature. All work related non-minor injuries must be recorded. Work related first degree burns and pinhead sized second degree burns are considered minor injuries and not recordable by nature. However, first degree burns and pinhead sized second degree burns, like any other minor injury, are recordable if they involve medical treatment (other than first aid), loss of consciousness, transfer to another job, or restriction of work or motion (see pages 28 and 43 of the Guidelines).
Q3. Same scenario as above, but the blister appears on the day of injury. Does blistering of a burn have to be immediate to be classed as a second degree burn or can there be a lag time for the blister to appear?
A3. The blister does not need to appear immediately to classify the burn as second degree.
Q4. Same scenario as case 1, only this time no follow-up is given to the injured's condition and the blister is not discovered. Is this case recordable?
A4. Deciding if injuries and illnesses are recordable entails making decisions based on available information. Information from medical, hospital, or supervisor records should be reviewed along with other pertinent information when making decisions regarding all of the aspects in evaluating injury and illness cases. The employer is responsible for recording cases no later than 6 working days after receiving information that a recordable case has occurred. If there is no information indicating that a recordable case has occurred, the employer has no case to record.
I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463.
Division of Recordkeeping Requirements