Special Topics in Safety Management

Are You Keeping Sharps and Bloodborne Pathogens Exposure Records?

Usually, if you’re not subject to the program requirements of a standard, you’re not subject to its recordkeeping requirements, either. Bloodborne pathogens exposure is an exception. You may not be required to have a bloodborne pathogens exposure control program, but OSHA’s recordkeeping standard requires all employers to keep records of sharps exposure incidents, and some nonsharps exposure incidents, that occur at work.

So, even if accidents and emergencies are such an unlikely occurrence in your workplace that you don’t even have workers who are trained in first aid (who would be covered by the bloodborne pathogens standard), you still need to be aware of the recordkeeping standard’s requirements.

Exposures in Low-Risk Workplaces

One of the safest places in America to work is a college campus, and one of the safest jobs to hold is that of professor. That’s why it was such a terrible shock when, in 2010, University of Alabama-Huntsville biology professor Amy Bishop  pulled out a 9- millimeter handgun during a faculty meeting and started shooting. Three professors died, and two more professors and a staff assistant were wounded. In a situation like that, it is entirely possible that people who are not trained in first aid and had no expectation of bloodborne pathogens exposure could be exposed, while tending the wounded, before emergency personnel arrive.


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Even if the cause is something less dramatic—perhaps a worker slips on a wet office floor and suffers a cut to the head; perhaps a school custodian is accidentally exposed to a diabetic student’s improperly discarded sharps—the employer is responsible for recording those exposure incidents.

OSHA’s recordkeeping rule 29 CFR 1904.8 requires that all employers, whether  they are covered by the bloodborne pathogens standard, record all work-related needlesticks and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material (OPIM) on the 300 Log as an injury. Because these are “privacy cases”—bloodborne diseases are a privacy issue for workers—you must not record the employee’s name on your 300 Log. If the employee is later diagnosed with an infectious bloodborne disease, the identity of the disease must be entered, and the classification must be changed to an illness.


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For exposures that do not involve cuts or punctures—for example, if an employee is splashed with or touches blood or OPIM, the incident must be recorded on the OSHA 300 if it results in the diagnosis of a bloodborne illness or if it meets the other recording criteria found in the recordkeeping standard.

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