Needlestick injury recordkeeping

Yes — you must record all work-related needlestick injuries and cuts from sharp objects that are contaminated with another person's blood or other potentially infectious material on the OSHA 300 Log. The regulation states you must enter the case on the OSHA 300 Log as an injury, but you may not enter the employee’s name on the OSHA 300 Log when the case meets the privacy-case rules. See Recording criteria for needlestick and sharps injuries in 1904.8(a) and the privacy-case rules referenced in 1904.29(b)(6)–(9).

It means human bodily fluids, tissues, organs, and other materials that can carry bloodborne pathogens, including laboratory cultures and tissues from experimental animals infected with HIV or HBV. OSHA points employers to the Bloodborne Pathogens definition in 1910.1030(b); see the implementation examples in 1904.8(b)(1).

No — you only record those cuts, lacerations, punctures, and scratches if they are work-related and involve contamination with another person's blood or other potentially infectious material. If the injury involves a clean object or a contaminant that is not blood or another potentially infectious material, you record it only if it meets one or more of the general recording criteria in 1904.7. See 1904.8(b)(2).

Yes — you must update the OSHA 300 Log. If a recorded injury later results in the diagnosis of an infectious bloodborne disease, update the case description to identify the disease and change the case classification from an injury to an illness if the case results in death, days away from work, restricted work, or job transfer. See 1904.8(b)(3).

You must record the incident as an illness only in two situations: if the exposure results in the diagnosis of a bloodborne illness (for example, HIV, hepatitis B, or hepatitis C) or if it meets one or more of the recording criteria in 1904.7. This is set out in 1904.8(b)(4)(i)–(ii).

No — to protect privacy you may not enter the employee’s name on the OSHA 300 Log when the case is a privacy case. The rule at 1904.8(a) requires recording the case but refers employers to the privacy-case provisions found in 1904.29(b)(6)–(9) for when names must be withheld from public logs.

Yes — laboratory cultures and tissues from experimental animals infected with HIV or hepatitis B virus are specifically listed as examples of other potentially infectious material and are recordable when they contaminate a sharps injury. See 1904.8(b)(1)(ii) and the Bloodborne Pathogens rule at 1910.1030(b).

You determine recordability by applying the general recording criteria in 1904.7: a case is recordable if it involves medical treatment beyond first aid, days away from work, restricted work, job transfer, or death. For distinguishing first aid from medical treatment, use the definitions in 1904.7(b)(5). OSHA’s interpretation about paraffin wax explains how a specific therapy (heat via paraffin) is treated as first aid for recordkeeping when used alone; consult that guidance when exposures are treated with hot/cold therapy. See 1904.7 and OSHA’s letter on paraffin wax as medical treatment (https://www.osha.gov/laws-regs/standardinterpretations/2024-10-22).

No — if heated paraffin wax is used alone to treat a work-related injury or illness, that treatment is considered first aid and the case is not recordable. OSHA’s interpretation explains that heated paraffin wax is a form of hot therapy and therefore falls within the first-aid examples in [1904.7(b)(5)(ii)(E)]. See 1904.7 and OSHA’s Letter of Interpretation on paraffin wax (https://www.osha.gov/laws-regs/standardinterpretations/2024-10-22).

Yes — if a recorded injury later results in a diagnosis of an infectious bloodborne disease and the case meets recordable thresholds (death, days away, restricted work, or job transfer), you must update the OSHA 300 Log to change the classification from injury to illness and revise the description to identify the disease. See 1904.8(b)(3).

Yes — employers may use software-generated forms that are equivalent to OSHA Forms 300 and 300A as long as the electronic forms contain the same information, are as readable and understandable, and are completed using the same instructions as the OSHA forms. OSHA’s interpretation on software-generated forms clarifies that equivalent forms and computerized records are acceptable when they meet the requirements in 1904.29 (see the Letter of Interpretation on software-generated forms (https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29)).

Yes — electronic records and equivalent forms must be able to produce the same information for inspection and copying by authorized government representatives and must be made available to employees or their representatives in accordance with recordkeeping-access rules. OSHA’s software-generated-forms interpretation explains that electronic systems are permitted provided they can produce equivalent forms when needed to comply with access requirements in 1904.29 and related access provisions. See the Letter of Interpretation on software-generated OSHA recordkeeping forms (https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29).

Record the event as an illness if the splash exposure results in a diagnosis of a bloodborne illness such as hepatitis C. 1904.8(b)(4)(i) requires recording such exposures as illnesses when they lead to a diagnosed bloodborne disease. If the exposure does not lead to diagnosis, you must still check whether it meets the general recording criteria in 1904.7.

Not automatically — a sharps injury from a clean object is recordable only if it meets one or more of the general recording criteria in 1904.7 (for example, if it results in days away from work, restricted work, medical treatment beyond first aid, or death). OSHA explains this distinction in 1904.8(b)(2).

You may record the event initially as an injury when it is a needlestick; however, if the case later results in a diagnosed infectious bloodborne disease and meets the thresholds for death, days away, restricted work, or job transfer, you must update the OSHA 300 Log to change the classification from an injury to an illness and identify the disease. See 1904.8(b)(3).