Are Sharps Injury Logs Required for Healthcare Practices?

Are Sharps Injury Logs Required for Healthcare Practices?

In healthcare settings, sharps safety is a daily concern — and so is understanding what OSHA requires when it comes to injury documentation. Many medical, dental, and outpatient practices wonder whether they need to keep a separate Sharps Injury Log in addition to their regular OSHA records. This article explains what the Sharps Injury Log is, when it’s required, how exemptions based on size or industry apply under federal OSHA, and highlights a key exception for certain states.

What Is a Sharps Injury Log?

A Sharps Injury Log is a confidential record used to document each percutaneous injury from a contaminated sharp (for example, a needle, scalpel, or other device that penetrates the skin). Under the federal Bloodborne Pathogens Standard, the log is intended to help employers identify patterns, evaluate safer device options, and reduce injury risk.

At minimum, a compliant log typically includes:

• The type and brand of device involved in the incident
• The department or work area where the exposure occurred
• A brief explanation of how the incident happened

While the Sharps Injury Log is separate from OSHA’s 300-Series injury and illness records, it serves a similar purpose: tracking injuries so hazards can be corrected.

Who Is Required to Keep It? (Federal OSHA)

Under federal OSHA, the requirement to maintain a Sharps Injury Log applies only to employers who are required to keep OSHA’s injury and illness records under 29 CFR Part 1904. In other words, if you are exempt from OSHA’s 300/300A/301 recordkeeping, you are also exempt from the Sharps Injury Log requirement under federal OSHA.

OSHA Recordkeeping Exemptions (Federal)

• 10 or fewer employees: Employers that had 10 or fewer employees at all times during the previous calendar year are generally exempt from maintaining OSHA injury and illness records.
• Partially exempt industries: Certain low-hazard industries (based on NAICS codes), including many outpatient healthcare settings such as offices of physicians and dentists, are partially exempt from the 300-series recordkeeping rules.

What This Means for Most Outpatient Practices

If your practice meets either exemption (≤10 employees or is in a partially exempt NAICS industry such as physician or dental offices), you are generally not required to maintain OSHA’s 300 Log, 300A Summary, or 301 Incident Reports — and you are likewise not required to keep a Sharps Injury Log under federal OSHA. That said, keeping a simple sharps log is still a best practice to support safety and demonstrate a proactive compliance posture.

Important Exceptions: Practices in California (Cal/OSHA) and Washington (WISHA)

Some states operate their own occupational safety and health programs and impose additional requirements beyond federal OSHA. Practices in these states must follow their state-specific rules for sharps injury logging.

California (Cal/OSHA): Under Cal/OSHA’s Bloodborne Pathogens Standard (8 CCR 5193), any employer with occupational exposure to blood or other potentially infectious materials must establish and maintain a Sharps Injury Log. This requirement applies even if the practice would otherwise be exempt from federal OSHA’s 300-series recordkeeping due to size or industry.

Washington State (WISHA): Washington’s Bloodborne Pathogens rule (WAC 296-823) similarly requires all employers with occupational exposure to maintain a Sharps Injury Log. This requirement applies regardless of federal OSHA exemptions and must be followed by any practice covered under WAC 296-823.

Bottom line for California and Washington: If your practice has occupational exposure as defined by 8 CCR 5193 (California) or WAC 296-823 (Washington), you are required to maintain a Sharps Injury Log — even if you qualify for federal OSHA’s partial exemptions under Part 1904.

What Should Healthcare Practices Do?

1. Assess exposure: Determine whether employees have occupational exposure to blood or other potentially infectious materials (OPIM) based on job duties and procedures.
2. Confirm recordkeeping status (federal): Identify whether you are exempt from federal OSHA 300-series recordkeeping (≤10 employees or partially exempt NAICS). Remember, this federal exemption does not remove the sharps injury log requirement in California and Washington.
3. Implement or update your Sharps Injury Log: If required (or as a best practice), ensure entries capture the device type/brand, work area, and brief incident description, and that confidentiality is protected.
4. Review trends and controls annually: Use your log to identify patterns, evaluate safer medical devices, and update your Exposure Control Plan accordingly.

Key Takeaway

For many outpatient medical or dental practices, federal OSHA exemptions mean you may not be required to maintain a Sharps Injury Log. However, in California and Washington, practices with occupational exposure must keep a Sharps Injury Log — even if they would otherwise be exempt from federal OSHA 300-series recordkeeping.

Supporting References

1. 29 CFR 1910.1030(h)(5) – Bloodborne Pathogens Standard: Sharps Injury Log
   

   “The requirement to establish and maintain a sharps injury log shall apply to any employer who is required to maintain a log of occupational injuries and illnesses under 29 CFR part 1904.”

2. 29 CFR 1904.1 and 1904.2 – Partial Exemption for Size and Industry
   Employers with 10 or fewer employees, or operating within a partially exempt NAICS industry, are not required to maintain injury and illness records.
3. OSHA Compliance Directive CPL 02-02-069 (2001) – Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard
   

   “Paragraph (h)(5) requires employers to establish and maintain a sharps injury log … Employers who are already partially exempt from Part 1904 recordkeeping requirements (see 29 CFR 1904.1 and 1904.2) are not required to keep a sharps injury log, but are encouraged to do so.”

   View Directive – PDF
4. OSHA Compliance Directive CPL 02-00-172 (2025) – Recordkeeping Policies and Procedures Manual
   Confirms the continuing applicability of CPL 02-02-069 and that the sharps-log requirement follows the Part 1904 recordkeeping exemptions.
   View Directive – PDF
5. OSHA FAQ – Sharps Log Exemption
   

   “If an employer is exempted from the OSHA recordkeeping rule, the employer does not have to maintain a sharps log. For example, dentists’ offices and doctors’ offices are not required to keep a sharps log after January 1, 2002.”

   osha.gov/faq/8-1
6. 8 CCR 5193 – Cal/OSHA Bloodborne Pathogens Standard
   

   “The employer shall establish and maintain a Sharps Injury Log, which is a record of each exposure incident involving a sharp…”

   Applies to employers with occupational exposure under California’s standard, even if exempt from federal Part 1904 recordkeeping.
   View Regulation – California Code of Regulations, Title 8, Section 5193
7. Cal/OSHA Bloodborne Pathogens FAQ (Question 11) – Sharps Injury Log Requirement
   

   “A Sharps Injury Log is required by Section 5193. Employers with occupational exposure must maintain this log even if they are otherwise exempt from federal OSHA recordkeeping.”

   View FAQ – Department of Industrial Relations
8. Washington State (WISHA) – Bloodborne Pathogens Standard (WAC 296-823)
   

   “[Employers must] Maintain sharps injuries separately from other injuries and illnesses kept on the Injury and Illness Log as required by WAC 296-27, Recordkeeping and Reporting.
   View Regulation – WAC 296-823

9. OSHA Recordkeeping Exempt Industries (NAICS Codes)
   Confirms that outpatient healthcare facilities such as offices of physicians (NAICS 621111) and offices of dentists (NAICS 621210) are considered low-hazard and exempt from federal OSHA 300-series recordkeeping.
   View Exempt Industries List – OSHA.gov

How Gamma Compliance Solutions Can Help

Gamma Compliance Solutions packages include resources to help you complete your required OSHA documentation correctly and identify where exemptions may apply. Each package provides professionally developed templates, guidance documents, and examples tailored to medical, dental, and veterinary settings — helping your team stay inspection-ready.

You’ll also have direct access to OSHA-Authorized Trainers and compliance experts who can answer questions, clarify complex regulations, and guide you through the documentation process with confidence.