Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

May 24, 1993

Ms. Chris K. Moody, P.E.
Director, Industry Affairs
Gas Processors Association
6526 East 60th Street
Tulsa, Oklahoma 74145

Dear Ms. Moody:

Thank you for your letter dated April 21, requesting an interpretation on the proper recording of bloodborne pathogen injuries on the OSHA 200 Log. Your letter was forwarded to my office from the Directorate of Compliance Programs. The Office of Statistics is responsible for maintaining the injury and illness recordkeeping system nationwide.

For OSHA injury and illness recordkeeping purposes, an occupational bloodborne exposure incident shall be recorded if it meets one of the following requirements:

1. The incident involves loss of consciousness, transfer to another job, or restriction of work or motion; OR

2. The incident results in a diagnosis of seroconversion; OR

3. The incident results in the administration or recommendation of medical treatment beyond first aid (e.g. gamma globulin, hepatitis B immune vaccination, hepatitis B vaccine, or zidovudine) regardless of dosage.

Furthermore, for OSHA injury and illness recordkeeping purposes, an exposure incident is defined as a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious material. "Non-intact skin" includes skin dermatitis, hang-nails, cuts, abrasions, chafing, etc.

If an exposure incident, as defined above, does not occur, the case would not be recordable regardless of treatment rendered. If, however, the employee does experience an exposure incident (e.g. a splash to non-intact skin) and receives (or is recommended to receive) the hepatitis B vaccine, the case is recordable.

I hope you find this information helpful. If you have any further questions, please contact my staff at area code (202) 219-6463.


Stephen A. Newell
Office of Statistics