Recording hearing loss, burns and falls on injury logs

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

October 19, 1992

Darryl S. Addington, M.D.
Medical Director
Eastman Chemical Company
[Recipient address omitted]
Dear Dr. Addington:

Thank you for your letters dated October 7 and 9 requesting interpretations for several injury and illness recordkeeping issues. I will address each issue separately, and when possible, cite the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses.

Hearing Loss

If a worker is exposed to noise levels in excess of an 85 dB 8-hour time-weighted average, as found in the hearing conservation standard, any hearing loss is presumed to be work related. This presumption may be rebutted only with medical evidence that shows the entire shift in hearing was caused by non-occupational factors. A physician's written opinion stating that the loss was not caused, contributed to, or aggravated by the work environment is required. Documentation of the employee wearing proper hearing protection at all times in the high noise areas would not be enough to rebut the presumption. It must be shown that the shift was totally due to non-work factors.

A company that records a work related Standard Threshold Shift (STS) (defined as 10 dB or higher) would be in complete compliance with the injury and illness recordkeeping requirements. However, for federal enforcement purposes, a company will only be cited for not recording a cumulative shift of 25 dB or greater.

Burns

Non-pinhead work related second degree burns and all occupational third degree burns are recordable, regardless of the type of treatment given. As found on page 42 of the Guidelines, a non- minor injury is one that results in damage to the physical structure of a nonsuperficial nature. Second degree burns which are larger than a pinhead and all third degree burns are considered nonsuperficial for recordkeeping purposes. All work related non-minor injuries must be recorded.

Falls

The general rule is that all injuries and illnesses that occur to employees on the employer's premises are presumed to be work related. If an employee falls within the work environment, whether caused by a non-work related preexisting condition or not, any resulting injury from the fall would be considered work related. If the injury requires medical treatment, as per your example, the case would be recordable. Please see Q&A B-14 on page 31 and Q&A C-7 on page 34 of the Guidelines.

I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463.

Sincerely,
Stephen A. Newell
Director
Office of Statistics
Enclosure

[Requester letter reproduced on OSHA page; omitted here.]