In a recent interpretation letter, OSHA responded to an employer’s request for “clarification on whether an employee’s laceration and subsequent fainting at the sight of blood constitutes a recordable case on the OSHA Form 300.”

The employee had scratched his finger on a vinyl saw clamp at work. The injury was minor and the only first aid treatment sought was a Band-Aid. However, while a Band-Aid was being applied by a coworker, the injured employee fainted at the sight of his own blood. When he regained consciousness he explained what had happened, and with no additional injuries, no further treatment was needed.

Under 29 CFR 1904.7(b)(1)(v) “a work-related injury or illness must be recorded if it results in loss of consciousness.” Although the employee’s scratched finger was work-related, the question was whether the subsequent fainting was work-related and therefore recordable. OSHA pointed to Section 1904.5(a) which states, “[the employer] must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition.” (emphasis added) (There are exceptions for situations where a person’s loss of consciousness is due to a personal medical condition, such as epilepsy, where the loss of consciousness at work is 100% attributable to the medical condition.)

In this incident, if the employee’s only work-related injury had been his scratched finger, it would not have been recordable. However, Section 1904.5(a) applies to his corresponding loss of consciousness as a result of the scratched finger and, therefore, under 1904.7(b)(1)(v), his loss of consciousness is recordable.

The letter can be read in full here.