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California's Employer Records of Occupational Injury and Illness

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FAQs

14300.8 - Recording Criteria for Needlestick and Sharps Injuries 

Question 
What does "other potentially infectious material (OPIM)” mean?

Answer
The term is defined in the Cal/OSHA Bloodborne Pathogens standard at T8CCR 5193 and includes:
  • Human bodily fluids, tissues and organs, and
  • Other materials infected with HIV or the hepatitis B (HBV) or hepatitis C (HCV) viruses such as laboratory cultures or tissues from experimental animals. 

Question 
Does the term "sharps objects" only mean medical sharps such as a scalpel or does it include objects such as broken glass?

Answer 
For Cal/OSHA recordkeeping purposes, “sharp objects” include any sharp object that causes a cut, laceration, scrape or puncture wound, including broken glass, metal shards removed from a wound, or medical instruments. 


Question 
Must all work-related cuts, lacerations, punctures, and scratches be recorded?

Answer
No, do not record if they : 

  • involve a clean object, or 
  • are contaminated with a substance other than blood or OPIM, or
  • do not meet one or more of the general recording criteria in Section 14300.7  (e.g. death, days away from work, restricted work/job transfer, medical treatment beyond first aid, loss of consciousness).

Question 
What are some examples of cuts, lacerations, punctures and scratches that do not need to be recorded?

Answer
Cuts made by a knife, a laceration made by a dirty tin can, or a puncture with a greasy tool would not generally be recordable unless they were:

  • contaminated by blood or OPIM, or
  • resulted in death, days away from work, restricted work/job transfer, medical treatment beyond first aid, loss of consciousness.

Question 
Which cuts, lacerations, punctures, and scratches must be recorded?

Answer
Those which :

  • involve contamination with another person's blood or OPIM, or
  • meet one or more of the general recording criteria in Section 14300.7 (e.g.death, days away from work, restricted work/job transfer, medical treatment beyond first aid, loss of consciousness).

Question 
If I record a case and the employee is later diagnosed with an infectious bloodbome disease, does the Cal/OSHA 300 Log need to be updated?

Answer 
Yes, update the classification on the Cal/OSHA 300 Log if the case results in death, days away from work, restricted work, or job transfer. Also, update the description to identify the infectious disease and change the classification of the case from an injury to an illness.


Question 
If an employee is splashed or exposed to blood or OPIM without being cut or scratched, does it need to be recorded on the Cal/OSHA 300 Log?

Answer
Record the incident as an illness on the Log if it:

  • results in the diagnosis of a bloodborne illness, such as HIV, hepatitis B, or hepatitis C, or 
  • meets one or more of the recording criteria in Section 14300.7 (e.g. death, days away from work, restricted work/job transfer, medical treatment beyond first aid, loss of consciousness).

Question 
Can the Cal/OSHA 300 Log and 301 Form be used to meet the Cal/OSHA Bloodborne Pathogen Standard's requirement for a sharps injury log under T8CCR 5193.

Answer
Yes, provided the employer:

  • enters the type and brand of the device involved in incidents on either the 300 or 301 form, and
  • maintains the records in a way that segregates sharps injuries from other types of work-related injuries and illness, or allow sharps injuries to be easily separated.
  • if the sharp had engineered sharps injury protection, whether the protective mechanism was activated, and whether the injury occurred before the protective mechanism was activated, during activation of the mechanism or after activation of the mechanism, if applicable;
  • if the sharp had no engineered sharps injury protection, the injured employee's opinion as to whether and how such a mechanism could have prevented the injury; and
  • the employee's opinion about whether any engineering, administrative or work practice control could have prevented the injury

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