OSHA Releases Guidance on Reporting Amputations

By Roy Maurer Jan 21, 2015

The Occupational Safety and Health Administration (OSHA) clarified new injury reporting requirements for amputations in response to several questions submitted to the agency.

The Letter of Interpretation defines amputation 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; amputations of body parts that have since been reattached. Amputations do not include avulsions, enucleations, deglovings, scalpings, severed ears, or broken or chipped teeth.”

OSHA advised using a health care professional’s determination to distinguish between an amputation and an avulsion. If the diagnosis is avulsion, the event does not need to be reported. If the diagnosis is amputation, the event must be reported within 24 hours. 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, the agency said. Examples of avulsion that do not need to be reported include deglovings, scalpings, fingernail and toenail removal, eyelid removal, loss of a tooth, and severed ears.

OSHA clarified that the loss of a fingertip is considered an amputation and is reportable. “An amputation does not require loss of bone,” the agency said.

OSHA also clarified that the loss of an eye is the physical removal of the eye and is a reportable event. The loss of sight without the physical removal of the eye would not be reportable, however a case involving loss of sight that results in the inpatient hospitalization of the worker within 24 hours of the work-related incident is reportable.

OSHA interpretation letters explain requirements set by statute, standards and regulations but do not create additional employer obligations, the agency said.

Roy Maurer is an online editor/manager for SHRM.

Follow him @SHRMRoy

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