Recording bloodborne pathogen exposure incidents

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 20, 1992

Ms. Denise Tinkham, RN
[Recipient address omitted]
Dear Ms. Tinkham:

Thank you for your letter of February 6 asking about the proper recording of occupational exposures to hepatitis B and human immunodeficiency virus (HIV). Your letter was forwarded to me by the Bureau of Labor Statistics. Please excuse the lengthy delay in our response.

Question 1. Should all blood/body fluid exposures be recorded on the OSHA-200 log as injuries, or filed as first aid?

An occupational bloodborne pathogens exposure incident (e.g., needlestick, laceration or splash) shall be classified and evaluated as an injury since it is usually the result of an instantaneous event. It shall be recorded if it meeds one or more of the following requirements:

1. The incident results in a loss of consciousness, transfer to another job, or a work restriction, and/or

2. The incident results in medical treatment beyond first aid (e.g., gamma globulin, hepatitis B immune globulin, hepatitis B vaccine, zidovudine, or other prescription medications), and/or

3. The incident results in a diagnosis of seroconversion.

Testing or diagnostic procedures are not considered medical treatment for OSHA recordkeeping purposes. However, the results of such procedures may indicate the presence of a recordable injury or illness. For more discussion about the medical treatment/first aid treatment issue see pages 42-43 of the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses.

Each recordable injury is required to be entered into the OSHA records within 6 working days after receiving information that a recordable case has occurred. If the date of the event or exposure is known, the injury shall be recorded with the date of the event or exposure in column B of the 200 log. If there are multiple events or exposures, the injury shall be recorded using the date that the positive seroconversion was diagnosed (the test date).

In the case that a seroconversion is known, it shall be recorded on the OSHA 200 log as an injury (e.g., "needlestick, laceration etc"), not as a seroconversion. This approach allows the employer to record the case and provide access to other employees without revealing the seroconversion status of the affected worker.

Question 2. Should a contagious disease related to body contact exposure (scabies or lice) be recorded on the OSHA-200 log as an illness, category 7g "all other occupational illness" or filed as "first aid"?

As discussed on page 37 of the guidelines, conditions resulting from animal bites, such as insect or snake bites are to be considered injuries. Occupational injuries are recordable if the incident results in a loss of consciousness, transfer to another job, restriction of work or motion (including days away from work) and/or medical treatment beyond first aid.

I hope this information is useful to you. If you have any questions or concerns, please contact my staff at (202) 523-1463.

Sincerely,
Stephen A. Newell
Acting Director
Office of Statistics

Enclosure