Key Takeaways

- Overt emphasis on avoiding incident recordability creates a temptation to sacrifice or second-guess medical treatment to split the fine hairs of regulation, violating the ethics of care philosophy.

- Misapplied emphasis on OSHA recordability and a utilitarian mindset of zero accidents (zero recordables) can erode trust in the organization and ultimately damage the culture of safety.

- Injured employees must be cared for with their physical and mental health and well-being placed above any numerical evaluation of organizational safety metrics.

- Administrators tasked with OSHA recordkeeping decision-making should be insulated from the pressures to sacrifice employee care for the sake of safety performance metrics.


A few years ago, while working as a safety manager for a midsized regional corporation, the author found herself in a conference room with three fellow safety managers and the director for corporate safety and health arguing over whether to report an injury on the OSHA 300 log. The case details were somewhat unusual: The employee had walked into a doorframe in the company lunchroom and suffered a laceration to the forehead that required sutures. This experienced group of safety professionals disagreed about the proper course. Some thought that because the employee was on a lunch break, the person was not in the course and scope of employment. Others felt that because the incident occurred on company property at the end of the break and the employee was headed back to their desk, the case should be recorded.

During this spirited conversation, what the author found odd was the extent to which resources were devoted to the question itself. Approximately half a million dollars of annual salaries were sitting in the room spending at least an hour trying to decide whether to fill out a government form. No one was concerned about paying the medical bills. There was little discussion about the root causes of the incident; the employee was looking at a mobile device reading an email when they walked into a doorframe. The foremost issue was whether the case should be counted as an OSHA recordable case, a category of workplace injury that must be reported and recorded according to federal OSHA recordkeeping rules. This decision would impact the organization’s yearly safety goal and everyone’s annual bonus. As a safety professional, the issue of OSHA recordability has always left the author feeling unsettled and wondering whether the significance is misplaced.

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