OSHA Clarifies No Need for “Double” Reporting of Related Injuries/Illnesses

Under OSHA’s Recording and Reporting Occupational Injuries and Illnesses regulation, employers are required to affirmatively notify OSHA when an employee suffers a work-related hospitalization, amputation, or loss of an eye or an employee fatality. A fatality must be reported within eight hours and any in-patient hospitalization, amputation, or eye loss must be reported within twenty-four hours. Please see OSHA’s FAQs found here for additional information on what information must be reported and how to report it. See OSHA’s FAQ’s found here.

In a standard interpretation dated January 8, 2021, but more recently published, OSHA clarifies that employers are not required to “double” report injuries/illnesses for a second related event when the first has already been reported. By way of example, if an employer reports an in-patient hospitalization within 24 hours of learning about it and that same employee then undergoes surgery and passes away five days later due to the work-related injury, the employer is not required to report the fatality. The second example discusses the scenario where an employer reports an in-patient hospitalization within 24 hours and while hospitalized, the employee’s arm is amputated due to a work-related injury. The amputation would also not trigger an additional reporting obligation. A copy of the standard interpretation can be found here.

However, OSHA notes that covered employers must still record the most serious outcome for each case on its injury and illness records.

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