Does your practice need an OSHA sharps injury log?

What the log has to show

Where it applies, 29 CFR 1910.1030(h)(5)(i) says "The employer shall establish and maintain a sharps injury log for the recording of percutaneous injuries from contaminated sharps." The information must be kept "in such manner as to protect the confidentiality of the injured employee." At a minimum, the log contains:

• "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."

Who is partially exempt from OSHA injury records

Two separate exemptions in 29 CFR part 1904 can apply:

• Size (1904.1): "If your company had 10 or fewer employees at all times during the last calendar year, you do not need to keep OSHA injury and illness records unless OSHA or the Bureau of Labor Statistics informs you in writing that you must keep records"
• Industry (1904.2): Establishments in an industry group listed in Appendix A "do not need to keep OSHA injury and illness records unless the government asks you to keep the records"

Which health care industries are on the list

Appendix A to Subpart B lists these health care industries, among others:

• 6211 Offices of Physicians
• 6212 Offices of Dentists
• 6213 Offices of Other Health Practitioners
• 6214 Outpatient Care Centers
• 6215 Medical and Diagnostic Laboratories

Who is not on the list

Hospitals (6221-6223), nursing care facilities (6231) and veterinary services are not on that list. Unless the size exemption applies, those employers keep OSHA records, so the sharps injury log applies to them too.

The size exemption is counted across the whole company: "The partial exemption for size is based on the number of employees in the entire company." The industry exemption is counted per site: it "applies to individual business establishments."

What the exemptions don't change

The partial exemptions cover recordkeeping only. Both 1904.1 and 1904.2 keep the duty to report a fatality, in-patient hospitalization, amputation or loss of an eye to OSHA. The rest of the bloodborne pathogens standard, including the exposure control plan and training, is a separate set of duties. See What is an OSHA exposure control plan? and What bloodborne-pathogen training does OSHA require?.

Needlesticks on the OSHA 300 Log

For employers that keep records, 29 CFR 1904.8(a) says: "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." The case goes on the 300 Log "as an injury," and "you may not enter the employee's name on the OSHA 300 Log."

How long to keep it

1910.1030(h)(5)(iii): "The sharps injury log shall be maintained for the period required by 29 CFR 1904.33." That section requires saving the records "for five (5) years following the end of the calendar year that these records cover."

What this page does not decide

This guide does not assign your NAICS code, decide whether an exemption applies, or certify OSHA compliance. If your state runs its own OSHA-approved program, confirm its version of these rules. A waste pickup contract doesn't create or replace the log. Rule text: 29 CFR part 1904.

Is a doctor's or dentist's office exempt from the sharps injury log?

Offices of Physicians (6211) and Offices of Dentists (6212) are on OSHA's partially exempt list, so they don't keep OSHA injury records "unless the government asks you to keep the records." The log applies only to employers required to keep those records.

Does a veterinary clinic need a sharps injury log?

Veterinary services are not on the Appendix A list. A clinic with more than 10 employees at any time last year generally keeps OSHA records, and with them the sharps injury log.

What has to be in a sharps injury log?

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."

How long do you keep a sharps injury log?

Five years following the end of the calendar year the records cover, per 29 CFR 1904.33.

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