OSHA Recordkeeping Handbook - denix

§1904.8exposure” as these terms are defined in OSHA’sBloodborne Pathogens standard (29 CFR 1910.1030).These injuries are of special concern to healthcareworkers because they use needles and other sharpdevices in the performance of their work duties andare therefore at risk of bloodborne infections causedby exposures involving contaminated needles andother sharps. Although healthcare workers are at particularrisk of bloodborne infection from theseinjuries, other workers may also be at risk of contractingpotentially fatal bloodborne disease. Forexample, a worker in a hospital laundry could bestuck by a contaminated needle left in a patient’s bedding,or a worker in a hazardous waste treatmentfacility could be occupationally exposed to bloodbornepathogens if contaminated waste from a medicalfacility was not treated before being sent towaste treatment.Section 1904.8(a) requires employers to record onthe OSHA Log all work-related needlestick andsharps injuries involving objects contaminated (orreasonably anticipated to be contaminated) withanother person’s blood or other potentially infectiousmaterial (OPIM). The rule prohibits the employerfrom entering the name of the affected employee onthe Log to protect the individual’s privacy; employeesare understandably sensitive about others knowingthat they may have contracted a bloodborne disease.For these cases, and other types of privacy concerncases, the employer simply enters “privacy concerncase” in the space reserved for the employee’s name.The employer then keeps a separate, confidential listof privacy concern cases with the case number fromthe Log and the employee’s name; this list is used bythe employer to keep track of the injury or illness sothat the Log can later be updated, if necessary, and toensure that the information will be available if a governmentrepresentative needs information aboutinjured or ill employees during a workplace inspection(see Section 1904.40). The regulatory text ofSection 1904.8 refers recordkeepers and others toSection 1904.29(b)(6) through Section 1904.29(b)(10)of the rule for more information about how to recordprivacy concern cases of all types, including thoseinvolving needlesticks and sharps injuries. The implementationsection of Section 1904.8(b)(1) defines“other potentially infectious material” as it is definedin OSHA’s Bloodborne Pathogens Standard (29 CFRSection 1910.1030, paragraph (b)). Other potentiallyinfectious materials include (i) human bodily fluids,human tissues and organs, and (ii) other materialsinfected with the HIV or hepatitis B (HBV) virus suchas laboratory cultures or tissues from experimentalanimals. (For a complete list of OPIM, see paragraph(b) of 29 CFR 1910.1030.)Although the final rule requires the recording ofall workplace cut and puncture injuries resulting froman event involving contaminated sharps, it does notrequire the recording of all cuts and punctures. Forexample, a cut made by a knife or other sharp instrumentthat was not contaminated by blood or OPIMwould not generally be recordable, and a lacerationmade by a dirty tin can or greasy tool would alsogenerally not be recordable, providing that the injurydid not result from a contaminated sharp and did notmeet one of the general recording criteria of medicaltreatment, restricted work, etc. Paragraph (b)(2) ofSection 1904.8 contains provisions indicating whichcuts and punctures must be recorded because theyinvolve contaminated sharps and which must berecorded only if they meet the general recording criteria.Paragraph (b)(3) of Section 1904.8 containsrequirements for updating the OSHA 300 Log when aworker experiences a wound caused by a contaminatedneedle or sharp and is later diagnosed as havinga bloodborne illness, such as AIDS, hepatitis B orhepatitis C. The final rule requires the employer toupdate the classification of such a privacy concerncase on the OSHA 300 Log if the outcome of the casechanges, i.e., if it subsequently results in death, daysaway from work, restricted work, or job transfer. Theemployer must also update the case description onthe Log to indicate the name of the bloodborne illnessand to change the classification of the case froman injury (i.e., the needlestick) to an illness (i.e., theillness that resulted from the needlestick). In no casemay the employer enter the employee’s name on theLog itself, whether when initially recording theneedlestick or sharp injury or when subsequentlyupdating the record….The last paragraph (paragraph (c)) of Section1904.8 deals with the recording of cases involvingworkplace contact with blood or other potentiallyinfectious materials that do not involve needlesticksor sharps, such as splashes to the eye, mucous membranes,or non-intact skin. The final recordkeepingrule does not require employers to record these incidentsunless they meet the final rule’s general recordingcriteria (i.e., death, medical treatment, loss ofconsciousness, restricted work or motion, days awayfrom work, diagnosis by an HCP) or the employeesubsequently develops an illness caused by bloodbornepathogens. The final rule thus providesemployers, for the first time, with regulatory languagedelineating how they are to record injuries80OSHA RECORDKEEPINGHANDBOOK