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OSHA’s Health and Safety requirements : new recordkeeping and reporting for amputations [US]

The Occupational Safety and Health Administration (OSHA) released an interpretation letter dated December 16, 2014 on its new recordkeeping requirements that became effective on January 1, 2015. OSHA’s letter clarifies the types of injuries that must be reported to OSHA. 

OSHA interprets its new recordkeeping and reporting requirements

In response to OSHA’s new recordkeeping and reporting requirements, OSHA released an interpretation letter to clarify the new rules, which require amputations and the loss of an eye to be reported to OSHA.
  • Amputations must be reported to OSHA, but avulsions do not. Employers should first rely on the opinion of a health care professional on whether the injury is an amputation or an avulsion.
  • If an employer is unable to obtain a health care professional’s opinion, the employer should rely on the definition, which is the “traumatic loss of a limb or other external body part.”
OSHA does not require the loss of bone for an amputation, so if an employee loses the very tip of his or her finger, the injury must be reported.

Other new recordkeeping and reporting requirements

OSHA’s new recordkeeping and reporting requirements also require employers to report the loss of an eye. This requirement only requires employers to report the physical loss of an eye. Employers do not need to report the loss of eye sight if the eye is still attached, unless the loss of sight requires in-patient hospitalization. Red-on-line EHS Legal expert Sources: OSHA interpretation letter, “Clarification of the new reporting requirements contained in 1904.39,” December 16, 2014

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