OSHA Recordkeeping Handbook - Msabc.net

caused by contaminated needles and other sharps,and how they are to treat other exposure incidents(as defined in the Bloodborne Pathogens standard)involving blood or OPIM. “ Contaminated” is definedjust as it is in the Bloodborne Pathogens standard:“Contaminated means the presence or the reasonablyanticipated presence of blood or other potentiallyinfectious materials on an item or surface.” …After a review of the many comments in therecord on this issue, OSHA has decided to requirethe recording of all workplace injuries from needlesticksand sharp objects that are contaminated withanother person’s blood or other potentially infectiousmaterial (OPIM) on the OSHA Log. These cases mustbe recorded, as described above, as privacy concerncases, and the employer must keep a separate list ofthe injured employees’ names to enable governmentpersonnel to track these cases…....OSHA disagrees, believing that Congress mandatedthe recording of all non-minor injuries and illnessesas well as all injuries resulting in medicaltreatment or one of the other general recording criteria.OSHA finds that needlestick and sharps injuriesinvolving blood or other potentially infectious materialsare non-minor injuries, and therefore must berecorded. This conclusion is consistent with theSenate Committee on Appropriations report accompanyingthe fiscal year 1999 Departments of Labor,Health and Human Services, and Education andRelated Agencies Appropriation Bill, 1999 (S. 2440)which included the following language:Accidental injuries from contaminated needles andother sharps jeopardize the well-being of ourNation’s health care workers and result in preventabletransmission of devastating bloodborne illnesses,including HIV, hepatitis B, and hepatitis C. The committeeis concerned that the OSHA 200 Log does notaccurately reflect the occurrence of these injuries.The committee understands that the reporting andrecordkeeping standard (29 CFR 1904) requires therecording on the OSHA 200 Log of injuries frompotentially contaminated needles and other sharpsthat result in: the recommendation or administrationof medical treatment beyond first aid; death, restrictionof work or motion; loss of consciousness, transferto another job, or seroconversion in the worker.Accidental injuries with potentially contaminatedneedles or other sharps require treatment beyondfirst aid. Therefore, the Committee urges OSHA torequire the recording on the OSHA 200 log ofinjuries from needles and other sharps potentiallycontaminated with bloodborne pathogens (SenateReport 105-300).OSHA finds that these injuries are significant injuriesbecause of the risk of seroconversion, disease, anddeath they pose (see the preamble to the OSHABloodborne Pathogens Standard at 56 FR 64004)….OSHA disagrees with those commenters whoargued that the Section 1904.8 recording requirementwould be duplicative or redundant with the requirementsin the Bloodborne Pathogens standard (29CFR 1910.1030). That standard requires the employerto document the route(s) of exposure and the circumstancesunder which the exposure incident occurred,but does not require that it be recorded on the Log(instead, the standard requires only that such documentationbe maintained with an employee’s medicalrecords). The standard also has no provisionsrequiring an employer to aggregate such informationso that it can be analyzed and used to correct hazardousconditions before they result in additionalexposures and/or infections. The same is true forother medical records kept by employers: they donot substitute for the OSHA Log or meet the purposesof the Log, even though they may contain informationabout a case that is also recorded on the Log.OSHA is requiring only that lacerations and puncturewounds that involve contact with another person’sblood or other potentially infectious materialsbe recorded on the Log. Exposure incidents involvingexposure of the eyes, mouth, other mucous membranesor non-intact skin to another person’s bloodor OPIM need not be recorded unless they meet oneor more of the general recording criteria, result in apositive blood test (seroconversion), or result in thediagnosis of a significant illness by a health care professional.Otherwise, these exposure incidents areconsidered only to involve exposure and not to constitutean injury or illness. In contrast, a needlesticklaceration or puncture wound is clearly an injury and,if it involves exposure to human blood or otherpotentially infectious materials, it rises to the level ofseriousness that requires recording. For splashes andother exposure incidents, the case does not rise tothis level any more than a chemical exposure does. Ifan employee who has been exposed via a splash inthe eye from the blood or OPIM of a person with abloodborne disease actually contracts an illness, orseroconverts, the case would be recorded (providedthat it meets one or more of the general recordingcriteria).Privacy Issues…The final recordkeeping rule addresses this issueby prohibiting the entry of the employee’s name onthe OSHA 300 Log for injury and illness cases involv-§1904.8OSHA RECORDKEEPINGHANDBOOK81