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OSHA interpretation · 1992-07-02

OSHA recordability for dislocated joints.

← All interpretations§ 1904

OSHA’s standing caveat

Interpretation letters explain existing requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Enforcement guidance may be affected by later changes to OSHA rules, and a letter addresses the facts it was given — not necessarily yours.

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. Sincerely, STEPHEN A. NEWELL Acting Director Office of Statistics January 21, 1992 Louisiana Department of Labor Office of Employment Security - OSH 1001 North 23rd and Fuqua Baton Rouge, Louisiana 70804 Dear Sir: 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. Sincerely, John Stephens SHERT manager

Reproduced verbatim from osha.gov. US Government work, public domain (17 U.S.C. § 105).

Other letters on the same sections

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