Is It Recordable?
Scenario Q92

"Struck By" Foot Injury: is it recordable?

Verdict: Not recordable
Published 2020-10-11

Question

A 15lb piece of sheet metal falls four feet from a machine platform onto the foot of a machinist. He is seen by a nurse practitioner at an occupational health clinic who prescribes an x-ray. The x-ray reveals no bone fracture, but some degenerative bone loss is noted. The employee is prescribed over-the-counter ibuprofen, cold treatment, and returned to full duty. Is it recordable?

Answer

NO. The x-ray is considered diagnostic, which is not recordable. The OTC ibuprofen and cold treatment are considered first aid treatment. The employee did not miss any time and did not receive any work restrictions as he was returned to full duty.
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)(i)(B) The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils); or
1904.7(b)(5)(ii) What is "first aid"? For the purposes of Part 1904, \"first aid\" means the following:
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)(E) Using hot or cold therapy;

https://www.osha.gov/laws-regs/interlinking/standards/1904.7(b)(5)(i)

https://www.osha.gov/laws-regs/interlinking/standards/1904.7(b)(5)(ii)

https://www.osha.gov/laws-regs/interlinking/standards/1904.7(b)(5)(ii)(A)

Illustration for the scenario: "Struck By" Foot Injury

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This is guidance based on 29 CFR Part 1904 and OSHA letters of interpretation. Facts and details may be altered or fictional. As specified by OSHA, the employer is responsible for the final recordability determination.