- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
September 8, 1992
Ms. Juliana I. Nixon
H/S/E Information Analyst
The Quaker Oats Company
Post Office Box 9001
Chicago, Illinois 60604-9001
Dear Ms Nixon:
Thank you for your letter dated September 1 requesting information on the proper recording of a bloodborne pathogens case on the OSHA Log 200.
The bloodborne standard and the recordkeeping regulations are two separate rules and have different scopes of coverage. While the bloodborne standard applies to specific occupations, the injury and illness recordkeeping requirements cover all employees as defined in the OSH Act: "...one who is employed in the business of his employer" (see Q & A A-1, page 2, of the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses). As described in Q & A C-11, on page 35 of the Guidelines, coverage is intended to go beyond specific job tasks to encompass the total work environment.
For the situation described in your letter, the case must be recorded on the OSHA Log 200 whether the employee is covered by the bloodborne standard or not. The work exposure and resulting treatment meet the recordability criteria outlined in the enclosed Instruction CPL 2-2.44.
I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 523-1463.
Stephen A. Newell
Office of Statistics
September 1, 1992
U.S. Department of Labor
200 Constitution Ave. NW
Room # N3644
Washington, D.C. 20210
Per our conversation on August 23rd, l would like to get some documentation on the recordkeeping issues as they relate to OSHA's bloodborne pathogens standard.
We had an incident at a Quaker Oats facility where an employee was exposed to another employee's blood while performing her normal job duties, which do not involve providing first aid or any type of emergency care. The medical treatment given to the exposed employee consisted of a hepatitis B immune globulin shot. The question was raised whether the recent bloodborne pathogens standard and associated recordability requirements include employees other than first responders and health services personnel.
Please advise us in writing and we will forward the information to the appropriate people.
Thank you for your help on this issue.
Juliana I. Nixon
H/S/E Information Analyst