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Documenting an exposure incident
  • Employers must document the circumstances of an exposure incident in sufficient detail, as well as either identifying the source individual or explaining why that person can’t be identified.

Following an exposure incident, employers are required to document, at a minimum, the route of exposure and the circumstances under which exposure occurred. Documenting the circumstances surrounding an incident allows the employer to identify and correct hazards.

To be useful, the documentation must contain sufficient detail about the incident. There should be information about the following:

  • Engineering controls in use,
  • Work practices followed,
  • The device being used,
  • Protective equipment or clothing worn at the time,
  • The location of the incident,
  • The procedure being performed, and
  • The employee’s training.

Additional information might also include a comparison of similar occurrences and recommendations to avoid future incidents; although, this is not mandatory.

The employer must also document in writing the identity of the source individual, or the reasons that identification is not feasible. Examples of when it may not be feasible to identify the source individual:

  • Incidents of needlesticks caused by unmarked syringes left in laundry,
  • Incident involving blood samples that are not properly labeled, and
  • Incidents occurring where state or local laws prohibit such identification.