Q33 - Avulsion Injury

Question: 

An administrative assistant is using a paper cutter at work and slices the pad of her middle finger tip off. At a clinic, the doctor diagnosis the laceration as an avulsion and assures the admin assistant that the skin of the pad will grow back with proper care. The doctor instructs the employee how to keep the wound clean, recommends Neosporin and bandaging, and prescribes over-the-counter ibuprofen at over-the-counter strength. The employee returns to work at full duty. Is it recordable?

Answer:

NO. The injury resulted in first aid treatment only. The employee did not lose any time at work and, per OSHA, avulsions are not considered amputations. Therefore, this is injury is not reportable as an amputation and not recordable.

1904.7(a), Letter of Interpretation, 1904.39(b)(11), 1904.39(b)(8)

1904.7(a) Basic requirement. You must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. You must also consider a case to meet the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.

Letter of Interpretation: How do you distinguish between an amputation and an avulsion? (...) If and when there is a health care professional's diagnosis available, the employer should rely on that diagnosis. If the diagnosis is avulsion, the event does not need to be reported. If the diagnosis is amputation, the event must be reported. If there is no available diagnosis by a health care professional, the employer should rely on the definition and examples of amputation included in the regulatory text of Section 1904.39(b)(11). Examples of avulsion that do not need to be reported include deglovings, scalpings, fingernail and toenail removal, eyelid removal, loss of a tooth, and severed ears. Remember, employers are required to report amputations to OSHA when they learn that the reportable event occurred. The employer must report the event when he or she has information that the injury is a work-related amputation. See, Section 1904.39(b)(8).