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Recording needlestick injuries on the OSHA 200 log

Summary A medical center asked when a work-related needlestick injury had to appear on the OSHA 200 log. OSHA said the older rule required recording when the event involved restricted work, job transfer, unconsciousness, treatment beyond first aid, or seroconversion. Washing the puncture with soap and water alone did not meet those criteria; OSHA now archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-09-20-0
Date issued
September 20, 1996
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping Needlesticks
Source
View the official document

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 20, 1996

Ms. Rosie Ward
Director of Human Resources
Holzer Medical Center
[Recipient address omitted]
Dear Ms. Ward:

Thank you for your letter dated August 26, requesting guidance on the proper recording of needlestick injuries on the OSHA 200 Log. A work related 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.

If the needle stick only results in a thorough cleaning with soap and water as outlined in your letter, it does not meet the above recording criteria and should not be recorded on the OSHA Log.

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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