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September 20, 1996

Ms. Rosie Ward
Director of Human Resources
Holzer Medical Center
100 Jackson Pike
Gallipolis, Ohio 45631-1563

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