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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

June 7, 1993

Mr. Roger Reid, CAE
Southern Gas Association
Suite 1300, L.B. 60
3030 LBJ Freeway
Dallas, Texas 75234

Dear Mr. Reid:

Thank you for your letter dated March 30, stating your concerns regarding the recordability of bloodborne pathogenic exposure incidents 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 the administration of the injury and illness recordkeeping system nationwide.

An occupational bloodborne pathogens exposure incident shall be classified and evaluated as an injury since it is usually the result of an instantaneous event. It 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.

For recordkeeping purposes, "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..." In addition, "non-intact skin" includes skin with dermatitis, hang-nails, cuts, abrasions, chafing, etc. Therefore, cases involving an "exposure incident" to an employee may be recordable while cases involving a splash to a person's "intact" skin are not recordable.

Under 29 CFR 1904, medical treatment includes treatment that is actually provided as well as treatment that is clearly required but not provided. Thus, recommended treatment need not be rendered to satisfy the recordability criteria. This guidance can be found on page 44 of the Recordkeeping Guidelines, Q&A F-5. This is why Section J(2) of CPL 2-2.44c includes "...the recommendation of medical treatment..." in its recordability requirements. Once there is an exposure incident, for recordkeeping purposes, any treatment rendered or recommended is not considered preventative or prophylactic and must be evaluated as either medical treatment or first aid.

Recordability under the OSHA injury and illness recordkeeping system is not based on occupation or job title. All employees of the employer are equally covered by the recordkeeping regulations.

At the present time we are drafting a Notice of Proposed Rulemaking (NPRM) to revise the recordkeeping regulations, supplemental instructions and forms. As part of that proposal, we will ask the public to comment on all issues involved, including the recording of bloodborne pathogenic incidents. When the NPRM is published in the Federal Register, I hope you will provide us with any insights or comments you might have.

I hope this information is useful to you. If you have any questions or concerns, please contact my staff at (202) 219-6463.


Stephen A. Newell
Office of Statistics