• Employers must record all work-related needlestick injuries or cuts from sharp objects that are contaminated with blood or other potentially infectious material.
• If the injured employee is later diagnosed with an infectious bloodborne disease, the case will need to be updated in the OSHA 300 Log from injury to illness.

Employers should record all work-related needlestick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material (as defined by the Occupational Safety and Health Administration’s [OSHA] Bloodborne Pathogens standard at 1910.1030). Such cases should be recorded on the OSHA 300 Log as an injury; however, to protect the employee’s privacy, the employee’s name should not be entered on the OSHA 300 Log. Instead, the employer should enter “privacy case” in the space normally used for the employee’s name.

If the injured employee is later diagnosed with an infectious bloodborne disease, the employer should update the classification of the case on the OSHA 300 Log if the case results in death, days away from work, restricted work, or job transfer. The description should be updated to identify the infectious disease and change the classification of the case from an injury (a needlestick) to an illness (that resulted from the needlestick).

The employer should record incidents where employees are splashed with or exposed to blood or other potentially infectious material without being cut or scratched only if it results in the diagnosis of a bloodborne illness, such as HIV, hepatitis B, or hepatitis C; or if it meets one or more of the general recording criteria.

Employers may use the OSHA 300 and 301 forms to meet the sharps injury log requirement at 1910.1030(h)(5) in the Bloodborne Pathogens standard. To fulfill this requirement, an employer should enter the type and brand of the device causing the sharps injury on either form and maintain records in a way that segregates sharps injuries from other types of work-related injuries and illnesses, or allows sharps injuries to be easily separated.

What are other potentially infectious materials?

Other Potentially Infectious Materials (OPIM) means (1) The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids; (2) Any unfixed tissue or organ (other than intact skin) from a human (living or dead); and (3) HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.

Must all cuts, lacerations, punctures and scratches be recorded?

Employers need to record cuts, lacerations, punctures, and scratches only if they are work related and involve contamination with another person’s blood or other potentially infectious material. If the cut, laceration, or scratch involves a clean object, or a contaminant other than blood or other potentially infectious material, an employer should record the case only if it meets one or more of the general recording criteria.