Given the ever-present exposure to needlestick and sharps injuries, it is probably no surprise that the question often arises, “When do I need to record these types of injuries on our OSHA 300 Log?”   We hope to reveal the answers to this arcane mystery, in this article.

WAC 296-27-01109 provides guidance for the what’s and when’s of needlestick and sharps injury reporting.  Be aware that the Department’s regulations on injury reporting, for OSHA 300 Log purposes, are in flux, at the moment, and electronic reporting will likely be in effect soon.  This is because L&I is attempting to bring its regulations into line with Federal OSHA’s regulations.  The most recent draft of those new regulations; however, does not substantively change the current regulation on needlesticks and sharps injuries.

In determining whether you need to report needlestick and sharps injuries, the regulations break these types of injuries into two classifications:

1. Needlestick and sharp object cuts that are contaminated with another person’s blood or potentially infectious material.
2. Cuts, lacerations, punctures and scratches with clean objects or with contaminants other than blood or a potentially infectious material.

Recording Requirements for Needlestick and Sharps injuries with Contamination Exposure

You must record all work-related needlestick and sharps injuries that are contaminated with another person’s blood or other potentially infectious material.   Each of these incidents must be entered on the OSHA 300 log as an injury.

Due to the potentially sensitive nature of these types of injury exposures, to protect the employee’s privacy you may not record the employee’s name on the log.

If after initially recording the needlestick or sharps injury, it is determined that the employee has been diagnosed with an infectious bloodborne disease, the following two items on the OSHA 300 Log must be updated if the disease results in death, days away from work, restricted work or job transfer.

1. Change the classification of the case from an injury to an illness claim; and,
2. Change the description of injury to identify the infectious disease.

Recording Requirements for Cuts, Lacerations, Punctures and Scratches not Involving Contamination Exposure

When an employee suffers a cut, laceration or scratch involving a clean object with no exposure to blood or other potentially infectious material, then you need to record the case on your OSHA 300 log only if it meets the general reporting requirements for other injuries and disease located at WAC 296-27-01107 including injuries or illnesses that result in:

1. Death;
2. Days away from work;
3. Restricted work or transfer to another job;
4. Medical treatment beyond first aid;
5. Loss of consciousness for any length of time;
6. A significant diagnosed injury or illness such as the following even if there is no death, days from work, restricted work or medical treatment for the condition:
   1. Work related cancer;
   2. Chronic irreversible disease;
   3. Fractured or cracked bone;
   4. Punctured eardrum.