Many employers are currently asking themselves an important question: Do I need to record employee cases of COVID-19 on my OSHA injury and illness recordkeeping logs?
The answer to this question depends on each specific situation. In May 2020, the Occupational Safety and Health Administration (OSHA) issued a guidance memorandum to help employers make COVID-19 recordkeeping determinations. An employer will need to take action to determine whether employee COVID-19 illnesses are work-related and thus recordable.
Under OSHA’s recordkeeping requirements, COVID-19 is a recordable illness, and employers are responsible for recording cases of COVID-19, if:
Once the first step is complete and the illness is confirmed to be COVID-19, an employer must next determine if it was work-related. An injury or illness is considered to be work-related if an event or exposure in the work environment (as defined by 29 CFR § 1904.5(b)(1)) either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness.
Because it may be difficult to determine work-relatedness, OSHA will consider the following factors:
If after a reasonable and good faith effort was made and the employer cannot determine that the case was work-related, the employer does not need to record the COVID-19 illness.
If the case has been determined to be work-related, an employer must then determine if the case meets general recording criteria. An injury or illness meets the general recording criteria if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. Refer to 29 CFR 1904.7 to make the determination.
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