Is It Recordable?Amputated Earlobe: is it recordable?
Question
On a drilling rig, an oil field employee suffers an ear laceration that has taken off the lobe of his right ear. The ear is surgically repaired at the ER and the employee is released the same day. The incident took place on a Friday and the employee returned to work on his next scheduled shift without missing any time. The employee received prescription pain medicine during the procedure along with antibiotics. The stitches will be removed in one month. The doctor did not place any work restrictions on the employee. Is it recordable?
Answer
YES. Due to the prescription medicine and stitches the employee received during the surgery, the incident must be recorded. However, this is not a lost time injury as the employee did not miss any time. Further, the injury is not considered an amputation and the employer did not have to contact OSHA within 24 hours to report an amputation. Ears are not considered appendages that have to be reported to OSHA.
1904.7(b)(5)(i)
What is the definition of medical treatment? "Medical treatment" means the management and care of a patient to combat disease or disorder. For the purposes of Part 1904, medical treatment does not include:
1904.7(b)(5)(ii)(A)
Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
1904.7(b)(5)(ii)(D)
Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
From the interpretation letter regarding amputation reporting:
Question 1: Please provide the definition of an amputation.
Response: An amputation, for OSHA reporting purposes, is defined under section 1904.39(b)(11). "An amputation is the traumatic loss of a limb or other external body part. Amputations include a part, such as a limb or appendage that has been severed, cut off, amputated (either completely or partially); fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; amputations of body parts that have since been reattached. Amputations do not include avulsions, enucleations, deglovings, scalpings, severed ears, or broken or chipped teeth."
https://www.osha.gov/laws-regs/interlinking/standards/1904.7(b)(5)(i)
https://www.osha.gov/laws-regs/standardinterpretations/2014-12-16
