Do Med Spas Need an OSHA 300 Log?
Most med spas don't have to keep the OSHA 300 injury and illness log, but every employer has to report serious injuries, and a needlestick is a recordable injury for those who do keep the log. Here's how to tell which rules apply to you.
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The short answer
You don't need to keep the OSHA 300 log, the 300A annual summary or 301 incident reports if either of these is true, unless OSHA or the Bureau of Labor Statistics tells you in writing to keep them:
- Your company had 10 or fewer employees at all times during the last calendar year.
- Your establishment is in an industry OSHA lists as partially exempt. The list includes offices of physicians (NAICS 6211), offices of other health practitioners (6213) and personal care services (8121), the classifications med spas usually fall under.
What every employer must still do
The exemptions cover recordkeeping, not reporting. Every employer, however small and whatever its industry, must report to OSHA:
- A work-related death, within 8 hours.
- A work-related in-patient hospitalization, amputation or loss of an eye, within 24 hours.
If you do have to keep the log
| Rule | What it says |
|---|---|
| What to record | Work-related injuries and illnesses that meet OSHA's recording criteria, such as days away from work, restricted work, or medical treatment beyond first aid. |
| Needlesticks | All work-related needlesticks and cuts from sharps contaminated with another person's blood or other potentially infectious material, recorded as injuries without the employee's name. |
| How fast | Within 7 calendar days of learning about a recordable case. |
| Annual summary | Post the 300A summary from February 1 to April 30 of the following year. |
| How long to keep | Five years after the end of the year the records cover. |
Needlesticks and the sharps injury log
Employers who must keep OSHA injury records must also keep a sharps injury log under the Bloodborne Pathogens Standard, recording the device type and brand, the work area and how the injury happened. Even if you're exempt, a sharps injury log is worth keeping: your annual exposure control plan review is expected to consider safer devices, and the log shows which ones are causing injuries.
Questions
Is a med spa exempt from OSHA recordkeeping?
Usually. Med spas generally fall under offices of physicians, offices of other health practitioners, or personal care services, which are all on OSHA's list of partially exempt industries. Clinics with 10 or fewer employees all last year are exempt by size. Either way, OSHA or BLS can still ask you in writing to keep records, and serious injuries must always be reported.
Does a needlestick have to go on the OSHA 300 log?
If you're required to keep the log, yes: every work-related needlestick or cut from a sharp contaminated with another person's blood or other potentially infectious material is recorded, as a privacy case without the employee's name.
Where do I get the OSHA 300 log form?
OSHA publishes the 300, 300A and 301 forms on its website. You can also use an equivalent form with the same information. Exempt employers don't need them unless OSHA or BLS asks.
Sources
- OSHA, Partial exemption for employers with 10 or fewer employees, 29 CFR 1904.1
- OSHA, Partial exemption for establishments in certain industries, 29 CFR 1904.2
- OSHA, Partially exempt industries, 29 CFR 1904 Subpart B Appendix A
- OSHA, Recording criteria for needlestick and sharps injuries, 29 CFR 1904.8
- OSHA, Forms, 29 CFR 1904.29
- OSHA, Annual summary, 29 CFR 1904.32
- OSHA, Retention and updating, 29 CFR 1904.33
- OSHA, Reporting fatalities and severe injuries, 29 CFR 1904.39
General guidance, not legal or medical advice. Requirements vary by state; follow your medical director and product labels.