Is a Needlestick Injury Recordable on the OSHA 300 Log?

Yes, when the employer must keep OSHA injury records. Under 29 CFR 1904.8, every work-related needlestick and cut from a sharp object contaminated with another person's blood or other potentially infectious material is recorded on the OSHA 300 Log as an injury, without the employee's name. Employers that keep the log must also maintain a sharps injury log.

Recording rule. 29 CFR 1904.8(a) requires recording all work-related needlestick injuries and cuts from sharp objects contaminated with another person's blood or OPIM. The case is entered as an injury and treated as a privacy case, so the employee's name is not entered on the OSHA 300 Log.

Clean sharps. A cut from a clean object, or one contaminated with something other than blood or OPIM, is recorded only if it meets the general recording criteria in 1904.7 (1904.8(b)(2)).

Later diagnosis. If the employee is later diagnosed with a bloodborne disease, the case is updated from an injury to an illness, and the classification is updated if the case results in death, days away, restricted work or job transfer (1904.8(b)(3)).

Splashes. A splash or exposure without a cut is recorded as an illness if it results in diagnosis of a bloodborne illness such as HIV, hepatitis B or hepatitis C, or meets the general recording criteria (1904.8(b)(4)).

Sharps injury log. Employers required to keep an OSHA 300 Log must also maintain a sharps injury log of percutaneous injuries from contaminated sharps. It must record at least the type and brand of device, the department or work area, and how the incident occurred, and it must protect the injured employee's confidentiality (29 CFR 1910.1030(h)(5)). It is kept for the period in 1904.33, which is five years following the end of the calendar year covered.

Who keeps logs. Companies with 10 or fewer employees at all times during the previous calendar year, and establishments in certain partially exempt industries, generally do not need to keep OSHA injury records unless OSHA or the Bureau of Labor Statistics asks in writing (29 CFR 1904.1 and 1904.2).

Learn Laws® is a training company, not a law firm. This FAQ is general information, not legal advice.