Job13
Sign inCheck a case

OSHA interpretation · 1996-09-20

Guidance on the proper recording of needlestick injuries 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 20, 1996 Ms. Rosie Ward Director of Human Resources Holzer Medical Center 100 Jackson Pike Gallipolis, Ohio 45631-1563 Dear Ms. Ward: Thank you for your letter dated August 26, requesting guidance on the proper recording of needlestick injuries on the OSHA 200 Log. A work related needlestick injury shall be recorded if it meets one or more of the following requirements: 1. The incident results in a loss of consciousness, transfer to another job, or a work restriction, or 2. The incident results in the administration or recommendation of medical treatment beyond first aid (e.g., gamma globulin, hepatitis B immune globulin, hepatitis B vaccine, zidovudine, or other prescription medications), or 3. The incident results in a diagnosis of seroconversion. If the needle stick only results in a thorough cleaning with soap and water as outlined in your letter, it does not meet the above recording criteria and should not be recorded on the OSHA Log. I am enclosing our latest memoranda providing clarification on recording cases involving bloodborne pathogens on the OSHA 200 Log. I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463. Sincerely, Bob Whitmore Chief Division of Recordkeeping Requirements

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.