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.”