OSHA delays enforcement of new recordkeeping rule

Premier Safety Share
OSHA’s revised recordkeeping requirements took
effect on January 1, 2002, but enforcement of the
rule will be delayed for 120 days to allow OSHA
time for education and implementation. OSHA has
said that citations will not be issued during the
first three months of 2002, provided the employer
is attempting in good faith to meet its
recordkeeping obligations and agrees to make
corrections necessary to bring its records into
compliance. This final rule, the Occupational
Injury and Illness Recordkeeping Reporting
Requirements, and related forms issued on October
12, 2001, replaces the rule published in January
2001. It provides new definitions and reporting
criteria and requires the use of three new forms,
OSHA 300, 300A, and 301, or equivalent forms that
adhere to the reporting requirements (download
forms below). OSHA’s 300 and 301 forms can be
used to record contaminated sharps injuries,
provided all the requirements of the Bloodborne
Pathogen Standard are met, including details of
the injury (e.g., device type and brand and
description of injury) and the ability to easily
segregate the sharps injuries from other injuries.

A compliance directive, OSHA’s Recordkeeping
Policies and Procedures Manual (CPL 2-0.131), was
also issued to provide guidance on how the rule
will be enforced (download manual below).
Employers with fewer than 10 employees are exempt
from these regulations. The rule also delays for
one year a previously issued recordkeeping
requirement for occupational muscular skeletal
disorders (MSDs) or ergonomic injuries; MSDs are
recordable only if they meet OSHA’s recording
criteria for any other type of injury. OSHA
continues to work on defining ergonomic injuries
and may issue future regulations.

Recordkeeping related to contaminated sharps
injuries and other questions on the Bloodborne
Pathogen Rule are addressed in the frequently
asked questions (FAQs) on OSHA compliance (link
to FAQs below).

Downloads and links

Recordkeeping forms (918 KB)

Procedure manual (195 KB)

Frequently asked questions

Related information sharps injury prevention
Inspection procedures for bloodborne pathogen rule revised
Premier Safety Share
OSHA recently revised its Enforcement Procedures
for Occupational Exposure to Bloodborne Pathogens
(CPL 2-2 69) to incorporate sharps injury
prevention requirements spelled out in the
Needlestick Safety and Prevention Act of 2000
(download CPL below). These enforcement
procedures assure consistent and uniform
enforcement of the standard. Revisions include
all the changes made to the standard, including
methods for selection of devices with engineered
sharps injury prevention, involvement of non-
managerial workers in evaluation and selection
process, log of contaminated sharps-related
injuries, and annual review of the exposure
control plan. Also included are model exposure
control plans and updates on the Centers for
Disease Control and Prevention (CDC) management
of occupational exposures to HIV, HBV and HCV.
Frequently asked questions on OSHA compliance
with sharps safety are available (download FAQs

Downloads and links

OSHA Enforcement procedure CPL 2-2.69 (649 KB)

Other OSHA key documents

Frequently asked questions about OSHA

Jeff Hunsicker
HARRISBURG, December 11 – The Pennsylvania House
of Representatives unanimously today passed
legislation sponsored by Representative Dennis
O’Brien (R-Philadelphia) to protect public sector
health care workers from injuries caused by
unsafe needle sticks. On Monday, the Senate
unanimously passed HB 454, and the bill will now
go to Governor Schweiker for his signature.

Health care employees risk contracting diseases
such as HIV or Hepatitis when they are
accidentally stuck by needles on the job. In late
2000, President Clinton signed bipartisan
legislation requiring private health care
facilities to use needles that are designed to
protect health care workers from accidental
needle sticks. The law is administered by the
Occupational Safety and Health Administration,
but does not cover public sector employees.

District 1199P/Service Employees International
Union has pushed for over two to years pass
legislation to protect public sector workers. The
Union represents nearly 3,000 state and county
health care employees who work in state mental
health hospitals, prisons, county nursing homes,
and other facilities.

“Risking your health while caring for patients is
something no health care worker should have to
face,” said Marcy Boyer, a registered nurse at
Harrisburg State Hospital. “We worked with our
employer to implement a safe needle program even
before this legislation passed, and it’s made a
huge difference for myself and my co-workers. I’m
so happy that public sector workers throughout
the state will now be able to do the same.”

The law requires that public sector health care
facilities work with employees to evaluate and
choose safe needles. Facilities are then required
to switch to safe needles designed to protect
workers from accidental needle sticks.

Representing 15,000 nurses and other health care
employees in the state, District 1199P/SEIU is
the largest and fastest growing health care union
in Pennsylvania. It is affiliated with SEIU,
which represents 715,000 health care employees in
North America, and the SEIU Nurse Alliance, the
nation’s largest national union of nurses.