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Recordkeeping 201: Part 5, Needlestick and Sharps Injuries, Contact with Bodily Fluids

By Brian Zaidman, Research Analyst, Research and Statistics, Minnesota Department of Labor & Industry Reprinted from "Safety Lines: The Newsletter of Minnesota OSHA," January 2009.

Editor's note: This is the fouth installment of an occasional series of more advanced topics about recording occupational injuries and illnesses using the OSHA Form 300. This information is directed to people who are new to OSHA recordkeeping activities, who want to review their recordkeeping practices or who want to improve their recordkeeping skills. The previous series about recordkeeping, covering basic information about filling in the OSHA log and creating an annual summary is available at www.minnesotasafetycouncil.org/MO/articles.cfm.

Perhaps no single subject covered by the OSHA recordkeeping requirements produces more misunderstanding than the regulations concerning when and how to record injuries involving needles, sharp objects and contact with bodily fluids. The work I conduct with the Minnesota OSHA Workplace Safety Consultation unit's nursing home project and the survey team's review of OSHA 300 log data for the annual Survey of Occupational Injuies and Illnesses uncover many misconceptions health care industry employers have about what types of cases are recordable and how to record those cases.

What is a needlestick or sharps injury?
A cut, laceration, puncture or scratch caused by a clean needle or sharp object, one that has not been used to inject a health care patient, is not a needlestick injury. To be treated as a needlestick case, the needle – or other sharp object – must have first been used in or on another person's body or in contact with potentially infectious material before the wounding of the health care worker occurred.

The recordkeeping rule language, in section 1904.8, identifies work-related needlestick and sharps injuries as resulting from contact from objects that are contaminated with another person's blood or other potentially infectious material. Potentially infectious materials are defined in the OSHA Bloodborne Pathogens standard to include human bodily fluids, tissues and organs, and other materials infected with the HIV or hepatitis B virus, such as laboratory cultures or tissues. Wounds caused by needles and other sharp objects contaminated by a material other than blood or other potentially infectious material are included in this requirement.

How are needlestick and sharps injuries recorded?
All wounds caused by contaminated or potentially contaminated sharp objects must initially be recorded on the OSHA log as injuries. If the worker did not miss any time from work or require job restrictions or a job transfer, then the "other recordable" category is used. To protect the employee's privacy, the employee's name is not entered on the OSHA 300 log (see Recordkeeping 201, part 1 at http://www.minnesotasafetycouncil.org/MO/articles/recordkeeping201part1.cfm).

If a worker injured by a contaminated needlestick or sharp object is later diagnosed with a bloodborne illness, such as AIDS, hepatitis B or hepatitis C, then the classification of the incident should be changed to an illness. The type of case may also be changed to indicate the outcome of the case, such as death, days away from work, restricted work or job transfer. The case description should be updated to indicate the name of the bloodborne illness. The name of the employee must not be entered on the log.

What about other exposures?
Exposure to another person's blood or to other potentially infectious material does not, in itself, constitute an injury or illness. If the worker is splashed or exposed to blood or potentially infectious material without being cut or scratched, even a splash in the eyes or mucous membranes, then the incident is recorded on the OSHA 300 log only if it results in the diagnosis of a bloodborne illness or a positive blood test, or if it meets one of the other recording criteria, such as a job transfer, work restriction or days away from work.

Online Resources
Federal OSHA recordkeeping resources
  • www.osha.gov/recordkeeping/index.html


  • MNOSHA recordkeeping resources
  • http://www.dli.mn.gov/OSHA/Recordkeeping.asp


  • MNOSHA WSC recordkeeping training
  • http://www.dli.mn.gov/OSHA/PDF/rcdkpg4training.pdf


  • Survey of Occupational Injuries and Illnesses
  • www.bls.gov/iif

  • http://www.dli.mn.gov/RS/RatesTables.asp


  • Packet of recordkeeping forms, instructions
  • www.osha.gov/recordkeeping/RKforms.html


  • Booklet: Minnesota OSHA recordkeeping requirement
  • http://www.dli.mn.gov/OSHA/PDF/recordkeepingstandard.pdf
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