Job13
Sign inCheck a case

OSHA interpretation · 1992-09-08

Proper recording of bloodborne pathogens case on the OSHA 200 log.

← All interpretations§ 1904

OSHA’s standing caveat

Interpretation letters explain existing requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Enforcement guidance may be affected by later changes to OSHA rules, and a letter addresses the facts it was given — not necessarily yours.

September 8, 1992 Ms. Juliana I. Nixon H/S/E Information Analyst The Quaker Oats Company Post Office Box 9001 Chicago, Illinois 60604-9001 Dear Ms Nixon: Thank you for your letter dated September 1 requesting information on the proper recording of a bloodborne pathogens case on the OSHA Log 200. The bloodborne standard and the recordkeeping regulations are two separate rules and have different scopes of coverage. While the bloodborne standard applies to specific occupations, the injury and illness recordkeeping requirements cover all employees as defined in the OSH Act: "...one who is employed in the business of his employer" (see Q & A A-1, page 2, of the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses ). As described in Q & A C-11, on page 35 of the Guidelines, coverage is intended to go beyond specific job tasks to encompass the total work environment. For the situation described in your letter, the case must be recorded on the OSHA Log 200 whether the employee is covered by the bloodborne standard or not. The work exposure and resulting treatment meet the recordability criteria outlined in the enclosed Instruction CPL 2-2.44. I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 523-1463. Sincerely, Stephen A. Newell Acting Director Office of Statistics Enclosure September 1, 1992 David Schmidt U.S. Department of Labor 200 Constitution Ave. NW Room # N3644 Washington, D.C. 20210 Dear Dave, Per our conversation on August 23rd, l would like to get some documentation on the recordkeeping issues as they relate to OSHA's bloodborne pathogens standard. We had an incident at a Quaker Oats facility where an employee was exposed to another employee's blood while performing her normal job duties, which do not involve providing first aid or any type of emergency care. The medical treatment given to the exposed employee consisted of a hepatitis B immune globulin shot. The question was raised whether the recent bloodborne pathogens standard and associated recordability requirements include employees other than first responders and health services personnel. Please advise us in writing and we will forward the information to the appropriate people. Thank you for your help on this issue. Juliana I. Nixon H/S/E Information Analyst Suite 16-12

Reproduced verbatim from osha.gov. US Government work, public domain (17 U.S.C. § 105).

Other letters on the same sections

Deciding a case of your own?

The free recordability check works through Part 1904 in the order the regulation sets out and quotes the provision behind every step.

Check a case — free

Not legal advice. This page republishes 29 CFR Part 1904 as published by the eCFR and explains it. The recordkeeping duty is the employer’s. Where the rule requires judgement, Job13 says so rather than guessing — run your own case through the free check.