Scenario: You have an employee dislocate their finger at work. You send her to an occupational medicine clinic. While at the clinic, the physician performs a closed reduction procedure on her dislocated finger. It was determined that the employee had no broken bones, splints were not necessary, did not receive any medication, no restrictions were issued, and she returned to work immediately after the reduction procedure was performed on her finger.
Medical Note: Closed Reduction Procedure Explained – A dislocated finger can be corrected with or without injecting local anesthesia. To correct the dislocation, the doctor will press against the displaced bone to dislodge the bone if it is caught against the side of the joint. As the end of the bone is freed, the doctor can pull outward to restore the bone to its correct position. This is called closed reduction.
Based on the fact that employee had no broken bones, no medication, no splints, and no restrictions and she returned to work immediately after the reduction procedure was performed, you determine this falls under first aid treatment and is not an OSHA recordable.
Question: Did you make the right decision?
Answer: In an OSHA Letter of Interpretation dated June 26, 2013 to Ms. Brandi Behrnes with John L. Lowery & Associates, Inc., OSHA states “reduction is the care of a disorder not included on the first aid list under 1904.7(b)(5) and therefore it is considered medical treatment for OSHA recordkeeping purposes”.