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Needlestick injuries on the former OSHA Form 200

Summary A health care organization asked when needlestick injuries belonged on the former OSHA Form 200. OSHA listed the then-used triggers, including work restriction, medical treatment beyond first aid, or diagnosed seroconversion, and accepted the organization’s proposed method. OSHA archives the letter and warns it may no longer state current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1994-05-19-1
Date issued
May 19, 1994
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy.
Status last verified October 9, 2026

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OSHA labels this an archive document and warns that it may no longer represent current policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

May 19, 1994

Barbara J. Coyle, RN
CHAIS, Inc.
[Recipient address omitted]
Dear Ms. Coyle:

Thank you for your letter dated April 21 requesting guidance on the proper recording of needlestick injuries on the OSHA 200 Log. A needlestick injury shall be recorded if it meets one or more of the following requirements:

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

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

  3. The incident results in a diagnosis of seroconversion.

Upon review of the criteria outlined in your letter, we have determined that your method of recording needlesticks on the OSHA 200 Log is accurate and complete. If a case, upon investigation of lab values of the worker and the source patient, does not involve any of the above criteria it need not be recorded.

I am enclosing our latest memoranda providing clarification on recording cases involving bloodborne pathogens on the OSHA 200 Log. I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463.

Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements

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