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OSHA interpretation · 1993-04-01

Recording cases on the OSHA log that involve Bloodborne Pathogens.

← 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.

April 1, 1993 MEMORANDUM FOR: REGIONAL ADMINISTRATORS ATTENTION: REGIONAL RECORDKEEPING COORDINATORS THRU: LEO CAREY Director Office of Field Programs FROM: STEPHEN A. NEWELL Director Office of Statistics SUBJECT: Recording Cases on the OSHA Log that involve Bloodborne Pathogens The concepts and definitions for OSHA injury and illness recordkeeping for all private sector employers are contained in 29 CFR 1904, the instructions on the OSHA 200 Log, and the supplemental instructions contained in the Recordkeeping Guidelines for Occupational Injuries and Illnesses . For cases involving bloodborne pathogens, cases are recordable under 29 CFR Part 1904 when any employee experiences an "exposure incident" as defined below, that meets the criteria listed on page 6 of CPL 2- 2.44C (attached). Exposure Incident For recordkeeping purposes, "exposure incident" is defined as "a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious material..." In addition, "non-intact skin" includes skin with dermatitis, hang-nails, cuts, abrasions, chafing, etc. Therefore, cases involving an "exposure incident" to an employee may be recordable while cases involving a splash to a person's "intact" skin are not recordable. Recommendation of Treatment Under 29 CFR 1904, medical treatment includes treatment that is actually provided as well as treatment that is clearly required but not provided. Thus, recommended treatment need not be rendered to satisfy the recordability criteria. This is consistent with the recordkeeping practices relating to cases other than those involving bloodborne pathogens. This guidance can be found on page 44 of the Recordkeeping Guidelines, Q & A F- 5. For example, cases involving an employee's refusal to take prescription medication or to allow sutures to be applied do not change the recordability of the injury. This is why Section J(2) of CPL 2-2.44c includes "...the recommendation of medical treatment..." in its recordability requirements. Please make sure that your Bloodborne Coordinators are also made aware of this information.

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

Other letters on the same sections

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