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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 19, 1994

Barbara J. Coyle, RN
2558 South Williams Street
Milwaukee, Wisconsin 53207

Dear Ms. Coyle:

Thank you for your letter dated April 21 requesting guidance on the proper recording of needlestick injuries on the OSHA 200 Log. A 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.

Upon review of the criteria outlined in your letter, we have determined that your method of recording needlesticks on the OSHA 200 Log is accurate and complete. If a case, upon investigation of lab values of the worker and the source patient, does not involve any of the above criteria it need not be recorded.

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.


Bob Whitmore
Division of Recordkeeping Requirements