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OSHA Needlestick Policies

Unintentional needle sticks have always been an occupational hazard for nurses, phlebotomists, first responders and physicians; each incident carries the risk of blood-borne pathogens or diseases. In the 1990s, research established that transmission of the human immunodeficiency virus (HIV) is possible via blood and other body fluids; this prompted the health care field to begin to develop "needle-less" systems to lessen the potential for unintentional needlesticks. The Occupational Safety and Health Administration (OSHA) established specific policies regarding employee "needlestick and sharps injuries" following passage of the 106th Congress passage of Public Law 106-430 in November 2000.

  1. Basic Reporting Criteria

    • Every employer is required by law to record fatalities, injuries or illnesses that are work-related, a new case and meet other specific criteria applicable to certain fields of employment or injuries, including needlesticks. The records are kept on an OSHA Form-300 (see Resources).

    Work-Related Criteria

    • According to the OSHA website, an employer must consider a work injury "to meet the general-recording criteria," and thus, recordable if it results in any of the following: "death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid ... loss of consciousness;" or, a "significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness." The treatment for needlestick or a puncture in a health care setting qualifies as "medical treatment beyond first aid" when treated in an emergency department, occupational medicine or infectious disease setting.

    Needle-Related Criteria

    • Employers must record all needlestick injuries, punctures or cuts from sharp objects contaminated with another person's blood, bodily fluids, tissues, organs, laboratory tissues or animal- or human-derived cultures. The employee's name is not entered on the OSHA 300 Log to protect employee privacy. Injuries such as lacerations, cuts and punctures, are reportable only if they are work-related and expose the employee to the risk of contamination from fluids, cultures or tissues.

    Subsequent Updating Criteria

    • Employers are required to update the OSHA 300 log if an employee is later diagnosed with a blood-borne disease determined to be secondary to the original work-related needlestick or puncture.

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