Amputation Conversation - Because OSHA Wants to Know
Amputations are not pleasant to discuss for their grisly, ghastly, and gruesome nature. An amputation in the workplace is a terrible injury that deserves prompt attention to the extent that OSHA requires their reporting within 24 hours. The “within 24 hours” reporting requirement also pertains to inpatient hospitalization and eye loss with work-related fatalities to be reported within 8 hours of discovery.
But what exactly constitutes an amputation, apart from the obvious? From a fact sheet on reporting fatalities and severe injuries, OSHA defines an amputation as follows:
An amputation is defined as 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; and amputations of body parts that have since been reattached.
Now here’s where the conversation gets a bit “gross anatomy” in delineating an amputation from an avulsion as described in OSHA’s Q & As on their injury and illness recordkeeping requirements.
Q: How do you differentiate between an amputation without bone and avulsions?
A: 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. Examples of avulsion that do not need to be reported include deglovings, scalpings, fingernail and toenail avulsions, eyelid avulsions, tooth avulsions, 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.
At the risk of going out on a limb here, it just seems that when an amputation occurs in the workplace, there’s a lack of exposure control or a deficiency of some kind. Is the job safety analysis inadequate, is machine guarding missing, was the employee not wearing proper PPE, or did a part of the body get caught in the line of fire such as getting a finger crushed in placing masonry stones during hardscaping? Obviously, there’s a need to investigate the amputation incident and ensure corrective action is taken to prevent recurrence. In the calamity of dealing with the amputation mishap, an employer’s immediate reaction is to seek prompt medical attention for the injured worker. Secondarily, employers need to have an “amputation conversation” with OSHA because, well, the agency wants to know. The three options for reporting include electronically, by phone to the nearest OSHA area office, and by the 24-hour OSHA hotline at 1‑800-321-OSHA (6742).
For more information on severe injury and illness reporting, check out OSHA’s Recordkeeping page.
By Greg LaRochelle