- 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.
August 22, 1995
Ms. Lisann Rolle
Washington State Department
of Labor and Industries Division
of Research and Information Services
Post Office Box 44631
Olympia, Washington 98504-4631
Dear Ms. Rolle:
Thank you for you letter dated August 9, requesting several interpretations regarding OSHA injury and illness recordkeeping requirements. I will address your questions in the order they were presented and whenever possible, I will refer to the Recordkeeping Guidelines of Occupational Injuries and Illnesses by stating the appropriate page and Q&A numbers.
Q1. Are exposures with no documented injury or illness recordable?
A1. No. The OSHA injury and illness recordkeeping system is not designed to record exposure incidents. Q&A B-6 on page 30 states "Entries on the log...should be made only when the exposure results in a recordable work injury or illness." What must be determined is whether the employees have developed an abnormal condition (i.e. pertussis or meningitis) as a result of the exposure. Furthermore, Q&A B-9 on page 30 addresses the situation of receiving preventative care when not injured or ill.
Q2. Is possible exposure to rabies (involving no bite or other injury) recordable?
A2. No. See question 1 above.
Q3. An employee experiences a bloodborne pathogen exposure incident and receives a hepatitis vaccination booster as a result. Is this recordable?
A3. Yes. A work related bloodborne pathogen exposure incident shall be considered a case and would be recordable 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.
The booster the employee received must be considered medical treatment and therefore meets criteria 2.
Q4. If there is a possibility of a bloodborne pathogen exposure incident, but no definite exposure, which results in medical treatment, is it recordable?
A4. No. There must be a known bloodborne pathogen exposure incident to be considered a case.
Please be aware that OSHA is currently in the process of revising its injury and illness recordkeeping requirements. In doing so, we are addressing the issues you have raised in your letter concerning exposures in general and bloodborne pathogen exposure incidents. We anticipate publishing the proposed revision in the Federal Register this fall. I look forward to receiving any comments you may have regarding this matter at that time.
I hope you find this information useful. For further information concerning the recordability of bloodborne pathogen exposure incidents, please review the attached memoranda. If you have any further questions, please call us at Area Code (202) 219-6463.
Division of Recordkeeping Requirements