The OSHA sharps injury log, explained

One of the most reliably-cited findings in an OSHA inspection of a clinical setting, because a sharps injury log either exists or it doesn't — there is no partial credit.

Who this applies to

Any employer with employees who have occupational exposure to blood or other potentially infectious materials — which covers essentially every urgent care, primary care, dental, and ambulatory surgery practice — must establish and maintain a sharps injury log under the Bloodborne Pathogens Standard.

The log has to exist before an injury happens, not after. “We've never had a needlestick” is not an exemption — it just means the log has no entries yet. A surveyor asking to see it is asking whether the mechanism exists, not whether it has been used.

What has to be recorded

The type and brand of device involved — the regulation specifically asks for this, because it's what lets a clinic notice a pattern: three injuries from the same lancet brand is a purchasing decision, not three unrelated incidents.
The department or work area where it happened.
An explanation of how the incident occurred — the task in progress and the mechanism, not a narrative with names in it.

The confidentiality requirement is explicit. The standard requires the log be maintained “in such manner as to protect the confidentiality of the injured employee.” The safest way to do that is to never collect a name on the log in the first place — there's no confidentiality control to get wrong on a field that was never filled in.

Two things people get wrong

Recording a name. It feels natural to log who was hurt. The regulation asks you not to make that identifiable on the record — track it separately, not on the sharps log itself.
Treating it as optional below a certain size. The Bloodborne Pathogens Standard turns on whether any employee has occupational exposure, not on headcount — a two-provider clinic is covered the same as a large one.

Retention

Sharps injury log entries are employee exposure records, retained for at least 30 years under 29 CFR 1910.1020(d) — the general OSHA standard for access to employee exposure and medical records. (Medical records proper carry a longer duration — employment plus 30 years, under the same section's (d)(1)(i) — but a sharps log itself falls under the exposure- record provision at (d)(1)(ii), which is 30 years flat.) That's a long time to trust a binder in a back office.

The related record

A sharps injury is also a triggering event for a post-exposure evaluation under 29 CFR 1910.1030(f)(3) — a confidential medical evaluation and follow-up, made available immediately at no cost to the employee. The sharps log and the post-exposure evaluation are two different, related records; a clinic needs both, not one in place of the other.

Medicin Binder files this the same way, on a phone

One entry per injury, no name field, timestamped the moment it's filed rather than reconstructed later from memory — which is also the property a surveyor is actually checking for when they ask to see the log.

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