The California Sharps Injury Log: Section 5193(c)(2) Field by Field
Last reviewed Sep 1, 2026
A needlestick in a California hospital generates at least two records, and most programs only reliably produce one of them.
The short answer
Under 8 CCR §5193(c)(2), California employers keep a sharps injury log separate from the OSHA 300 Log, recording every exposure incident involving a sharp. Entries are made within 14 working days of the incident being reported, and the log is kept five years from the date of the incident.
Why it is a separate document
The two records exist for different reasons, and that explains why one cannot substitute for the other.
The 300 Log is the regulator's headline count of recordable cases. Under §14300.8 a needlestick goes on it as a privacy concern case, which means the employee's name comes off and is replaced with a case number.
The sharps injury log exists so that an employer can analyze and act. It records the device, how it failed, and what might have stopped it. It is a prevention document, and stripping it down to what the 300 Log holds would make it useless for the purpose the regulation gives it.
Federal OSHA requires a sharps log too, under 1910.1030. California's is more prescriptive, and Cal/OSHA inspects against it.
Tracking this in a spreadsheet?
carefoundryESC keeps employee health records, exposures and the OSHA 300 log in one place, and generates the forms from the records you already keep. Pricing is published; migration is included.
What each entry contains
- Date and time of the incident.
- Type and brand of the sharp involved. Brand, not just category, because the analysis is about which devices are hurting people.
- Job classification of the exposed employee.
- Department or work area where the incident occurred.
- The procedure being performed at the time.
- How the incident occurred.
- Body part involved.
- Whether the sharp had engineered sharps injury protection, and if so whether the protective mechanism was activated, and whether the injury happened before, during or after activation.
- The employee's opinion on whether such a mechanism could have prevented the injury, and whether any other engineering, administrative or work-practice control could have.
The field everyone skips
That last one. It is a required field, it is the employee's opinion rather than the clinician's, and it is the one most often left blank or filled in by whoever typed up the report.
There is a practical reason it goes missing. The record gets started while the employee is being treated, which is exactly the wrong moment to ask them to reflect on device design. Then the case closes and nobody comes back to it.
The fix is process, not paperwork: treat the entry as incomplete until the employee's own answer is in it, and give them a way to supply it later, in their own words, without coming back to occupational health. An employee self-service portal is a natural place for this, and it also produces a better answer than a paraphrase written by somebody else.
Fourteen working days
Working days, not calendar days, counted from when the incident was reported to the employer rather than from when it happened. Weekends do not count. Public holidays vary by employer, so if you are automating the count, be careful about assuming a holiday calendar on somebody else's behalf.
Retention
Five years from the date of the incident, per §5193(h)(3). Note this runs from the incident date, not from the end of the calendar year, which is how the OSHA 300 retention works. Two records of the same event, two different clocks.
Separately, the employee's medical record of the exposure and any post-exposure evaluation is a medical record under §3204, retained for the duration of employment plus thirty years. Destroying that at five years because the sharps log period expired is a serious and surprisingly common error.
Does every state require this?
No, and it is worth knowing which. Federal OSHA requires a sharps log under 1910.1030 for employers with employees who have occupational exposure. Some state plans go further and some do not: Washington, for example, folds sharps recording into the 300 rather than requiring a separate log.
If you operate in more than one state, do not standardize on whichever practice your largest site follows. That is how a site ends up keeping a log it does not need, or missing one it does.
A short checklist
- Confirm the log is separate from the 300, not a filtered view of it.
- Check you capture device brand, not just type.
- Check the engineered-protection question captures whether the mechanism was activated, not just whether it existed.
- Find out how many of last year's entries have the employee's own opinion recorded. If it is under half, that is your gap.
- Total the log by device and by department at least annually. A prevention log nobody totals is not doing its job.
carefoundryESC records the sharps detail on the exposure itself rather than in a second table, so one event cannot become two records that disagree about the date. The screen opens on incomplete entries, because that is the failure mode, and the device totals are on the page. It is part of the OSHA compliance baseline, available to any employer in any state.
Read the regulation
This is a summary. Read the current text of 8 CCR §5193 on the Department of Industrial Relations site before relying on it.