OSHA Guidance on Recording Work-Related COVID-19 (Coronavirus) Illnesses

The Occupational Safety and Health Administration (OSHA) requires most employers to record work-related illnesses and injuries. Within 29 CFR 1904.5(b)(2), OSHA spells out nine exceptions to this requirement, one of which is illness due to the common cold or flu (29 CFR 1904.5(b)(2)(viii)). However, other contagious diseases can be recordable when an employee is infected at work. COVID-19, the illness caused by the SARS-CoV-2 virus, is one of these diseases. The SARS-CoV-2 virus is a novel coronavirus that emerged in late 2019. This outbreak was declared a pandemic by the World Health Organization (WHO) on March 11, 2020.

  • On May 19, OSHA issued revised guidelines for recording COVID-19 cases on OSHA 300 injury and illness logs. This guidance became effective on May 26 and supersedes previous guidance issued on April 10.
  • Per the April 10 guidance, only employers in the health care industry, emergency response organizations and correctional institutions were required to make work-related determinations of COVID-10 cases. All other employers were exempt except in cases in which “objective evidence” existed that the case was work-related, or such evidence was “reasonably available” to the employer.
  • The May 19 revision broadens the scope to formally include all industries. As is the case with other illnesses or injuries, employers with 10 or fewer employees and certain employers in low-hazard industries have no COVID-19 illness recording obligations unless the illness results in a fatality or an in-patient hospitalization.
  • COVID-19 cases are recordable if all three of these conditions are met:
  1. The case is confirmed as COVID-19 (one or more of the employee’s respiratory specimens tested positive for SARS-CoV-2).
  2. The case is work-related as defined by 29 CFR 1904.5.
  3. The case involves one or more of the general 29 CFR 1904.7(b)(1) recording criteria:
    • Days away from work
    • Restricted work or transfer to another job
    • Medical treatment beyond first aid
    • Loss of consciousness
    • Significant injury or illness diagnosed by a physician or licensed health care professional
    • Death

OSHA states employers must make reasonable efforts based on the evidence available to them, to ascertain whether a case is work-related. Because of the difficulty of determining work-relatedness, OSHA offers the following guidance:

  • COVID-19 illnesses are likely work-related when several cases develop among workers who work closely together and there is no alternative explanation.
  • An employee’s COVID-19 illness is likely work-related if it is contracted shortly after lengthy, close exposure to a customer or coworker who has a confirmed case of COVID-19 and there is no alternative explanation.
  • An employee’s COVID-19 illness is likely work-related if the job duties include having frequent, close exposure to the general public in a locality with ongoing community transmission and there is no alternative explanation.
  • An employee’s COVID-19 illness is likely not work-related if they are the only worker to contract COVID-19 in the vicinity and the job duties do not include having frequent contact with the general public, regardless of the rate of community spread.
  • An employee’s COVID-19 illness is likely not work-related if they, outside the workplace, closely and frequently associate with someone (e.g., a family member, significant other, or close friend) who (1) has COVID-19; (2) is not a coworker, and (3) exposes the employee during the period in which the individual is likely infectious.

Learn more about OSHA’s recordkeeping requirements here.
Visit OSHA’s page on COVID-19 for more pandemic guidance from the agency.

Phone: 1.855.872.6742
Fax: 1.855.872.6742
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