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
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.
Federal OSHA recordkeeping resources
MNOSHA recordkeeping resources
MNOSHA WSC recordkeeping training
Survey of Occupational Injuries and Illnesses
Packet of recordkeeping forms, instructions
Booklet: Minnesota OSHA recordkeeping requirement