- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
July 2, 1992
Mr. John Stephens
SHERT Manager Conoco
3510 General DeGaulle Drive
New Orleans, Louisiana 70114
Dear Mr. Stephens:
Your letter dated January 21, requesting clarification of OSHA recordability for dislocated joints, has been forwarded to my office from the OSHA Dallas Regional Office. My Division of Recordkeeping Requirements is responsible for administering the OSHA injury and illness recordkeeping system nationwide. Please excuse the lengthy delay in our response.
As was pointed out in your letter, the Recordkeeping Guidelines for Occupational Injuries and Illnesses does not specifically address the subject of dislocations. These dislocations must be evaluated using the criteria found on page 42 of the Guidelines to determine if the injury is minor or not minor. Criteria (b) states that an injury is not minor if it impairs bodily function such as the normal use of limbs. Because a dislocation of a joint impairs the normal use of a body part, it would be considered a non-minor injury, and thus be a recordable case if work related.
I hope you find this information useful. If you have any further questions, please contact my staff at (202) 523-1463.
STEPHEN A. NEWELL
Office of Statistics
January 21, 1992
Louisiana Department of Labor
Office of Employment Security - OSH
1001 North 23rd and Fuqua
Baton Rouge, Louisiana 70804
I am requesting clarification of the OSHA recordability of an alleged on the job injury which resulted in the dislocation of the employee's finger. The employee was sent to a doctor and the finger was reset. There were no bone fractures involved and the employee was released by the attending physician to return to work unrestricted. The U.S. Department of Labor's Recordkeeping Guidelines for Occupational Injuries and Illnesses, DMB No. 1220-0029 effective April 1986, does not address dislocations or medical attention where minor manipulations is used to reset dislocated joints.
My question is; if an employee's finger is dislocated in an alleged work related incident and the finger is reset or should have been reset by a physician, is it a recordable medical treatment case or a non recordable first aid case?
Your prompt reply will be greatly appreciated.