Sharps injury logs in dental offices

Who has to keep a sharps injury log

The sharps injury log sits inside the Occupational Safety and Health Administration (OSHA) bloodborne pathogens standard, and it does not stand on its own (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).

The rule ties the log to another set of rules. It applies to employers required to maintain a log of occupational injuries and illnesses under 29 CFR part 1904 (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).

So one question decides it: must this office keep OSHA injury and illness records at all? If it must, it keeps a sharps injury log alongside them (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).

Why a dental office is partially exempt

The injury and illness recordkeeping rules exempt some employers from keeping those records, and the list of partially exempt industries includes the NAICS 6212 line, “6212 Offices of Dentists” (OSHA injury and illness recordkeeping rules, 29 CFR part 1904).

For employers on that list, the rule reads: “you do not need to keep OSHA injury and illness records unless the government asks you to keep the records” (OSHA injury and illness recordkeeping rules, 29 CFR part 1904).

That gives a dental office two plain situations, and the difference between them is one thing only:

• When the government has not askedThe office keeps no OSHA injury and illness records, so it keeps no sharps injury log with them (OSHA injury and illness recordkeeping rules, 29 CFR part 1904).
• When the government has askedThe office keeps OSHA injury and illness records, and keeps a sharps injury log with them (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).

Nothing here says how often the government asks, or of whom. This page does not guess at that.

The rules, word for word

Every rule sentence on this page rests on three rows of the research pack behind it: OSHA-6, OSHA-5 and OSHA-4. Here they are exactly as written, each with where it sits in the regulations.

• “required to maintain a log of occupational injuries and illnesses under 29 CFR part 1904”

  OSHA-6 · 29 CFR 1910.1030(h)(5)(ii) · OSHA bloodborne pathogens standard

• “6212 Offices of Dentists”

  OSHA-6 · 1904 Subpart B App. A · OSHA injury and illness recordkeeping rules

• “you do not need to keep OSHA injury and illness records unless the government asks you to keep the records”

  OSHA-6 · 1904.2(a)(1) · OSHA injury and illness recordkeeping rules

• “Identification and documentation of the source individual, unless the employer can establish that identification is infeasible or prohibited by state or local law”

  OSHA-5 · 29 CFR 1910.1030(f)(3)(ii) · OSHA bloodborne pathogens standard

• “Kept confidential”

  OSHA-4 · 29 CFR 1910.1030(h)(1)(iii), (iv) · OSHA bloodborne pathogens standard, on employee medical records

• “for at least the duration of employment plus 30 years”

  OSHA-4 · 29 CFR 1910.1030(h)(1)(iii), (iv) · OSHA bloodborne pathogens standard, on employee medical records

What to record

Here the sources go quiet, and this page does not fill the silence with guesses. The rules quoted above say who keeps a sharps injury log. They do not say what an entry in it must contain.

What the pack does hold is the documentation around an exposure incident. Exposure follow-up includes identification and documentation of the source individual, unless the employer can establish that identification is infeasible or prohibited by state or local law (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).

The source individual is often a patient. That is why the identity stays in the follow-up record and not in the logbook.

Employee medical records are kept confidential, and the employer keeps them for at least the duration of employment plus 30 years (OSHA bloodborne pathogens standard, 29 CFR 1910.1030). They run on their own clock, separate from any sharps injury log.

Training records are a third set again. They are covered in our guide to OSHA bloodborne pathogens training records for dental offices.

A good sharps injury log stays factual and short: what happened, what was done about it, and no personal names.

Keep patient identities out of the logbook

Keep patient identities out of the logbook. When an exposure follow-up needs to name a source individual, that belongs to the follow-up documentation the standard describes, kept under its own rules (OSHA bloodborne pathogens standard, 29 CFR 1910.1030).

If an office needs to trace who was treated, it does that in its own patient chart. A good log carries the incident, not the people.

Dental Logbook will not store patient names or anything else about patients. It will not store employee medical records either.

Check your state plan

This page is built from federal sources. Its research pack holds no state-plan rules, so this page cannot say what a state plan requires on top of them.

If your office works under a state OSHA plan, check your state plan’s current rules before you act on anything here. The same goes for any state board rule that touches injury records.

What Dental Logbook will do

Dental Logbook is in development. It will keep a sharps injury log as its own record: one entry per injury, no patient names, no employee medical records, exportable whenever the office asks for it.

It will not tell anyone that they comply with anything. It keeps records; the judgment stays with the office.