
300 Log Question
We have an employee who had carpal tunnel in both wrists. WC denied the claims due to he started treating beyond 90 days before he reported the injury to us (our state law states the injury must be reported within 90 days of realizing it is a work related injury).
I still listed it as an OSHA log injury due to he had lost time and even though WC denied it we still considered it a work injury. My question, however, is since it is both wrists, should this be considered two different injuries for the OSHA log? He had surgery on one and will be getting surgery done on the other I believe this month.
Comments (7)

This can be a tricky one because you'd have to determine if the carpal tunnel in BOTH wrists was caused or aggravated by the workplace during the same general time frame. Did he complain of the carpal tunnel in both wrists at the same time? Or did he complain of carpal tunnel in one wrist on one day, then complain about it in the other wrist a month later? If they were both reported on the same day (or close proximity) AND you believe that his work contributed to the illness in both wrists at approximately the same time, then you would log it as one incident. Since carpal tunnel is an illness rather than an injury, it creates a gray area as far as determining when the illness took place due to it not being an instantaneous event/injury.
However, with that being said, I'd evaluate his work tasks to ensure both wrists could've been potentially affected by his job duties. For example, if all of his work (or the majority of it) is done with one hand, rather than two hands at the same time, I'd question whether or not the workplace either caused or aggravated the illness in both wrists verus just one wrist. Not saying that's the case, but those are just questions I would ask.
In the end, it wouldn't be any different if a worker fell off a roof and broke bones in his foot, leg, got stitches in his face, etc. You would log all of those injuries under the same event, rather than separate cases for each injured body part.
Keep in mind that although closely related, worker's compensation and OSHA recordability may not always be the same as far as the classification of this illness, so check with your state's worker's compensation laws to ensure you classify the illness properly on their end. As it pertains to OSHA recordability, it doesn't matter when the injury occured - once they report it to you and you determine it's work-related and meets the recording criteria, it's getting logged.

He reported both at the same time. The tech is our longest tenured employee (been here for over 30 years). Unfortunately, a lot of our long term techs based on the work are pretty beat up. It's transport refrigeration work so a lot of lifting and wrenching in contorted spaces. Only when I started have we begun looking at various ergonomic tools and such.
I have seen cases like this reported on the log as bilateral CTS, and when I was an OSHA compliance officer, and it was never questioned. I think if the source of the injury was the same for both wrists, ie repetitive motion trauma from doing work in your establishment, then the case could be reasonably recorded as one entry.

I agree with @Joann

I had a very similar experience when after I started with the City I work for. I happened to be in HR and our HR specialist told me, "Hey, I wanted to give you a heads-up that an employee is getting carpal tunnel surgery in both wrists next week."
"Funny, this is the first I've heard about this. Normally an employee would complain to their Supervisor or contact me. I would look at their workstation design and see if we could make some improvements. But since this is the first I have heard of this, I doubt WC will cover the claim on such short notice," I replied.
Now to the "rest of the story"...
Apparently, this Victim Services employee used to work in dispatch and had carpal tunnel surgery in the past. So when she experienced the same pain she took it upon herself to be seen by a doctor and get the surgery scheduled without notifying the Safety Manager. I was right in that WC denied the claim due to lack of reporting. But when the claim went to hearing the judge sided with the employee and covered both surgeries.
In reference to Drew's comment about, "...determining if the carpal tunnel in BOTH wrists was caused or aggravated by the workplace," I found out that in her spare time she does a lot of knitting and crocheting. But since her workstation (which was poorly setup) was not modified it was no wonder she experienced the same pain in her wrists.
Initially, we did not report it on our OSHA 300 but once WC covered the surgeries, I had to go back and add it the the recodkeeping file.
FYI we called the injuries as ONE injury and not two separate injuries b/c it was determined they both happened about the same time.