Can a doctor rely on a nurse to take a patient’s temperature?

British Columbia, Canada


The following excerpt is from Pinch (Guardian ad litem of) v. Morwood, 2016 BCSC 938 (CanLII):

In Aslin v. Otto, 2003 BCSC 658 (Aslin), the plaintiff was seriously injured in a logging accident and transported by ambulance to a very basic rural hospital where he was treated by the defendant doctor. The ambulance crew reported only about pulse and there was no suggestion of hypothermia. The doctor noted a record of pulse and blood pressure and continued to monitor those vital signs but did not notice until he was about to transfer the plaintiff to another hospital that the plaintiff’s temperature had never been recorded. The attending nurse then took the plaintiff’s temperature and it was well below normal. The plaintiff was then treated for hypothermia, amongst his other life threatening injuries, but he died in the transfer to another hospital. In consideration of the failure to take the plaintiff’s temperature, the court said that this was a nursing function according to the evidence and the doctor could rely on the nurse to perform this function. The doctor was not expected to know the temperature “until he reviews the nurse’s notes” (at para. 26). The nurse could have been expected to report any unusual vital signs and, if not done, the doctor would not be expected to know of any unusual vital signs “until he or she reviewed the nurse’s notes” (at para. 26). In Aslin, as soon as the doctor discovered that the temperature had not been recorded, he ordered it to be done. He was entitled to rely on the nurse to take vital signs unless the circumstances should have alerted him to a particular need to ascertain temperature.

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