Hello Jessica,

These are all great questions for a work environment, but because these are students, I don’t believe they are covered by OSHA. Correct me if I am wrong, but that is the way I learned it.

Pat Leach

Lab Manager

The University of Texas at Dallas

Richardson, TX  75080

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Jessica Martin
Sent: Tuesday, October 21, 2025 7:36 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: [DCHAS-L] Sensitization Event - OSHA Recordable? OSHA Reportable?

 

Hi All!

 

I’m curious to engage the hive mind of the DCHAS listserv on an issue I’ve been thinking about too much over the last few days. Apologies for the long post – and I’m sure only the OSHA reporting nerds will be interested – so feel free to scroll past if this isn’t you!

 

https://pubs.acs.org/doi/abs/10.1021/acs.joc.9b03280 

 

The first time I read the paper about the grad student who developed sensitization to the reagents with which she was working (linked above), I was a graduate student, and I looked at it from that perspective. I was glad that this person got the help they needed - and I used it in talks and trainings as a means of pointing out how important it is for us to take our own symptoms seriously - and to keep an eye on our lab mates since it is easier for us to dismiss concerns about our own health than it is to dismiss concerns about someone else's health.

 

I was rereading it the other day and now I am looking at it from the perspective of a safety professional. And I was curious to get feedback from this community. 

·      This person was a graduate student – which does seem important to keep in mind for this exercise.

·      My understanding is that the case described in this paper would not be an OSHA Reportable because it is not a fatality, in-patient hospitalization, amputation, or loss of an eye. Does everyone here agree with that interpretation?

·      There is a point in the paper in which the author comments that they should probably have called 911 but they didn’t. However, if they had called 911, I am thinking:

o   If they were treated onsite or at the ER then released, it would be an OSHA Recordable but not an OSHA Reportable.

o   If they were admitted to the hospital for treatment, then it would become an OSHA Reportable (as well as an OSHA Recordable).

·      Since they didn’t call 911, even if not an OSHA Reportable, I am struggling with whether this would be an OSHA Recordable. The graduate student in the paper did end up ending her experimental work inside of the lab and was able to work out an approach with her PI to complete her doctorate. Because of the nature of both the health issue and doctoral work, it is a bit tough for me to define what happened here in terms of the language around an OSHA Recordable. For example:

o   In going to an allergist, they did get medical treatment beyond first aid. However, it wasn’t so much to treat an illness as it was to identify an allergy – they did not get treatment for the allergy. So I’m thinking that this wouldn’t be a factor that would make this an OSHA Reportable.

o   Can we argue that they had days away from work? A doctoral student’s schedule is not normally so rigidly defined as to make it clear whether they had to take days away from work or not to recover from their attacks or go to the allergist. They simply could’ve rearranged their schedules for this.

o   We could argue that they did have restricted work or a transfer because they were no longer able to re-enter the lab and re-focused the rest of their doctoral work on activities outside of the lab. However, as a doctoral student, would this constitute a transfer or restricted work by OSHA Reportable standards?

o   Once the allergist confirmed that they did have sensitization to the reagents in their lab, is that considered a diagnosed illness? And now an OSHA Reportable?

 

And after working through that decision tree, would Worker’s Compensation come into play at any point?

 

If you are able to work through this with me, I would very much appreciate your time. If you would prefer to talk it through instead, please reach out to me to schedule a time to talk!

 

Thank you!

 

Jessica A. Martin, Ph.D.

323-327-3974

jmartin54321**At_Symbol_Here**gmail.com

 

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