In healthcare settings, sharps safety is a daily concern — and so is understanding what OSHA requires when it comes to injury documentation. Many medical and dental offices wonder whether they need to keep a separate Sharps Injury Log in addition to their regular OSHA records. This article breaks down what the Sharps Injury Log is, when it’s required, and how exemptions based on size or industry apply to healthcare practices.
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 or scalpel that penetrates the skin). It’s required under the Bloodborne Pathogens Standard, 29 CFR 1910.1030(h)(5), and is intended to help employers identify patterns of sharps injuries, evaluate safer device options, and prevent future incidents.
The log must include at least:
- The type and brand of device involved in the incident,
- The department or work area where the exposure occurred, and
- A brief explanation of how the incident happened.
While this log is separate from OSHA’s 300-Series Injury and Illness records, it serves a similar purpose — tracking injuries so employers can correct hazards and reduce risk.
Who Is Required to Keep It?
The requirement to maintain a Sharps Injury Log applies only to employers who are already required to keep OSHA’s injury and illness records under 29 CFR Part 1904. That means it’s tied directly to OSHA’s recordkeeping rules — and those rules contain important exemptions.
OSHA Recordkeeping Exemptions
Under 29 CFR 1904.1, employers that had 10 or fewer employees at all times during the previous calendar year are exempt from maintaining OSHA injury and illness records. Additionally, under 29 CFR 1904.2, certain low-hazard industries (based on NAICS codes) are also partially exempt.
Among those exempt industries are the offices of physicians and dentists (NAICS 621111 and 621210), along with similar outpatient healthcare settings. You can review the complete list of exempt industries in Appendix A to Subpart B of Part 1904.
What This Means for Medical and Dental Practices
If your practice meets either exemption —
- 10 or fewer employees, or
- Listed in an exempt NAICS industry such as physician or dental offices —
then you are not required to maintain OSHA’s 300 Log, 300A Summary, or 301 Incident Reports and are likewise not required to keep a Sharps Injury Log.
However, OSHA encourages all healthcare employers who use needles or sharps to keep a Sharps Injury Log voluntarily. Maintaining this record supports compliance with the Bloodborne Pathogens Standard’s broader intent — to protect workers from exposure to blood and other potentially infectious materials — and can help demonstrate good-faith effort during inspections.
Supporting OSHA References
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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.” -
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. -
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 -
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 -
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
Bottom Line
Physician and dental offices are generally exempt from maintaining a Sharps Injury Log under 29 CFR 1910.1030(h)(5) because they are also exempt from OSHA’s injury and illness recordkeeping rules under 29 CFR Part 1904.
Still, keeping a simple Sharps Log is a best practice — it supports workplace safety programs, helps identify problem devices or procedures, and demonstrates proactive compliance.
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.
