Q&A: Is an avulsion fracture a reportable or recordable injury?
Would an avulsion be considered a reportable and/or recordable injury? No stitches were required but a tetanus shot was administered.
OSHA has repeatedly stated in several letters of interpretation that an avulsion does not need to be reported to OSHA.
The OSHA rule at 29 CFR 1904.39(b)(11) also states specifically that an avulsion does not meet the definition of an amputation that is reportable to OSHA.
Also note in the OSHA letters that the agency advises using a health care professional’s determination to distinguish between an amputation and an avulsion. A written medical opinion may be the best option because it provides documentation that will support your decision to report or not.
Concerning whether the avulsion is recordable on the OSHA 300 forms, it’s not clear from the description in the question whether the tetanus shot was the only response to the avulsion. If the only response was the tetanus shot, then it is first aid only and therefore not recordable under OSHA injury and illness recordkeeping criteria. An avulsion, however, may be recordable on the OSHA 300 injury and illness recordkeeping forms if it meets other recording criteria:
- There is medical treatment beyond first aid
- The injury resulted in day(s) away from work, restricted work, or transfer to another job (DART)
- Diagnosis of a significant injury or illness by a physician or other licensed healthcare professional
Review the OSHA 300 injury and illness criteria for recording injuries, especially for the criteria for first aid that is not recordable, under 29 CFR 1904 Subpart C.
Document the determination by a licensed healthcare professional about the avulsion diagnosis, treatment, and recommendations for work restrictions, if any, to support your decision to record the incident or not on the OSHA 300 forms.
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