Ask the Expert, Recordkeeping

Ask the Expert: Standards for OPIM Recordability

In our latest installment of Ask the Expert, brought to you by the team of industry experts at EHS Hero®, we look at a recent question from a subscriber asking about OPIM recordability after a needlestick incident. See what the experts had to say. 

OPIM recordability

Q: For a needlestick incident, how does one determine “other potentially infectious material” (OPIM) for recordability if the needle was disposed of prior to manager notification? Can the team member recount the incident to determine OPIM? Furthermore, if the employee declines medical attention/treatment to confirm or deny the presence of OPIM, is it recordable?

For the purposes of recording needlestick and sharps injuries as required by the regulation at 29 CFR 1904.8, OSHA has adopted the definitions of “contaminated” and OPIM contained in the bloodborne pathogens standard at 29 CFR 1910.1030(b). A needle or other sharp object is considered contaminated if blood or OPIM is present or reasonably anticipated to be present on it. OPIM encompasses various human bodily fluids, including “all body fluids in situations where it is difficult or impossible to differentiate between body fluids,” as well as human tissues, organs, and other materials infected with the HIV or hepatitis B virus (such as laboratory cultures or tissues from experimental animals).

In a 2003 letter of interpretation, OSHA indicated that, as a general rule, needles and other sharps in the waste stream are considered to be contaminated for the purposes of the standard, stating that “if a sharp (e.g., syringe, lancet) is found in the waste stream, one must assume that it has been used to inject a medication or drug into a person and, by virtue of that action, is reasonably anticipated to have blood on it; therefore, it is a contaminated sharp.”

Inferring from the relevant definitions and OSHA’s quoted language above, unless the needle in the situation you describe was unquestionably clean and unused, it seems most likely that OSHA would consider this incident a recordable needlestick. The team member’s declination of medical treatment does not affect the recordability of the case. Because the bloodborne pathogens standard (and the associated recordkeeping requirement) is based on the presence or reasonably anticipated presence of blood or OPIM rather than the actual presence of pathogens, the ultimate outcome of any medical testing does not change whether the case must be recorded as a needlestick incident on the OSHA 300 log.