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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

September 20, 1996

Ms. Rosie Ward
Director of Human Resources
Holzer Medical Center
100 Jackson Pike
Gallipolis, Ohio 45631-1563

Dear Ms. Ward:

Thank you for your letter dated August 26, requesting guidance on the proper recording of needlestick injuries on the OSHA 200 Log. A work related 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.

If the needle stick only results in a thorough cleaning with soap and water as outlined in your letter, it does not meet the above recording criteria and should not be recorded on the OSHA Log.

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