Ask the expert: Sharps injury log exemption and bloodborne pathogens training

By: November 1st, 2011 Email This Post Print This Post

Q: If my company is exempt from recordkeeping because we are considered a low-hazard industry, are we still required to keep a sharps injury log for needlesticks? And is bloodborne pathogens training required if we are exempt from recordkeeping?

A: You are in an OSHA-designated low-risk industry—most medical and dental practices qualify—then you are exempt from keeping the sharps injury log, as long as you are under federal OSHA. Some state-administered occupational safety and health agencies make no recordkeeping exemptions.

Under federal OSHA, recordkeeping exemptions have no bearing on whether you must be compliant with the Bloodborne Pathogen standard, including the initial and annual training requirements.

For more details and links to OSHA references see the post, “Ask the expert—Bloodborne pathogens and small medical practice exemption.”


By Evelina Kissentaner on November 30th, 2011 at 7:53 pm

I’ve just began doing mobile Phlebotomy what would I need in my car other then my traveling gear.That has to remain in the car while working ?

By David LaHoda on November 30th, 2011 at 9:24 pm

A lot depends on whether you are an employee or a contractor, and whether “mobile phlebotomy” means your are going into homes as opposed other healthcare facilities. If the former, then NIOSH’s Occupational Hazards in Home Healthcare would be a good place to start, especially the checklist. Otherwise, I think you need to provide more details or link up with professional associations in phlebotomy such as the Center for Phlebotomy Education.


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