Recording a blood exposure outside designated first aid work

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 8, 1992

Ms. Juliana I. Nixon
H/S/E Information Analyst
The Quaker Oats Company
[Recipient address omitted]
Dear Ms Nixon:

Thank you for your letter dated September 1 requesting information on the proper recording of a bloodborne pathogens case on the OSHA Log 200.

The bloodborne standard and the recordkeeping regulations are two separate rules and have different scopes of coverage. While the bloodborne standard applies to specific occupations, the injury and illness recordkeeping requirements cover all employees as defined in the OSH Act: "...one who is employed in the business of his employer" (see Q & A A-1, page 2, of the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses). As described in Q & A C-11, on page 35 of the Guidelines, coverage is intended to go beyond specific job tasks to encompass the total work environment.

For the situation described in your letter, the case must be recorded on the OSHA Log 200 whether the employee is covered by the bloodborne standard or not. The work exposure and resulting treatment meet the recordability criteria outlined in the enclosed Instruction CPL 2-2.44.

I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 523-1463.

Sincerely,
Stephen A. Newell
Acting Director
Office of Statistics

Enclosure

[Requester letter reproduced on OSHA page; omitted here.]