Recordkeeping | Bloodborne Pathogens

OSHA requires that all needlestick and sharps injuries and illnesses that result from bloodborne pathogens exposure be recorded on the OSHA 300 Log, the sharps injury log, and employee-related medical and training records.

OSHA 300 Log

Revision 12/05 All occupational bloodborne pathogens exposure incidents that are work-related and involve contamination with another person’s blood or potentially infectious material, such as needlesticks and lacerations, must be recorded on the OSHA 300 Log as an injury. However, to protect an employee’s privacy, do not enter the name on the Log.

Medical records

A confidential medical record for each employee with potential for exposure must be preserved and maintained according to OSHA’s standard governing access to employee exposure and medical records at §1910.1020. This standard requires that medical records must be kept confidential and maintained for at least the duration of employment plus 30 years. Also, if you contract with a healthcare provider, the medical records may be kept at their worksite.

In addition, under the bloodborne pathogens standard, medical records also must include the following information:

• Employee’s name and social security number;

• Employee’s hepatitis B vaccination status, including dates of all hepatitis B vaccinations and any medical records related to the employee’s ability to receive vaccinations;

• Results of examinations, medical testing, and post-exposure evaluation and follow-up procedures;

• The employer’s copy of the health care professional’s written opinion; and

• A copy of information provided to healthcare professional.

Sharps injury log

Employers having workers with occupational exposure to BBP must establish and maintain a sharps injury log for the recording of percutaneous injuries from contaminated sharps. The information in the sharps injury log has to be recorded and maintained in such manner as to protect the confidentiality of the injured employee. The sharps injury log need to contain, at a minimum:

• The type and brand of device involved in the incident,

• The department or work area where the exposure incident occurred, and

• An explanation of how the incident occurred.

Revision 12/05 This applies to any employer who is required to maintain a log of occupational injuries and illnesses under OSHA’s injury and illness recordkeeping standard, part 1904. However, employers may use the OSHA 300 Log and 301 incident report to meet the sharps injury log requirements. To use the recordkeeping forms, the type and brand of the device has to be entered on either the 300 or 301 form, and the records must be maintained in a way that segregates sharps injuries from other types of work injuries. However, if you prefer to maintain a separate sharps injury log, there is a sample form on page 77 of this chapter.

Training records

The bloodborne pathogens standard also requires you to maintain and to keep accurate training records. Training records are not considered to be confidential and may be stored onsite where they are easily accessible. They must be retained for three years from the training date. Employee training records must include the following:

• Training dates,

• Content or a summary of the training,

• Names and qualifications of trainer(s), and

• Names and job titles of trainees.

Records access

Upon request, both medical and training records must be made available to both NIOSH and OSHA officials. Training records must be available to employees or employee representatives upon request. Medical records can be obtained only by the employee or anyone having the employee’s written consent.

Also, if an employer ceases to do business, medical and training records must be transferred to the successor employer. If there is no successor employer, the employer must notify the director of NIOSH for specific directions regarding disposition of the records at least three months prior to intended disposal.