On Safety: COVID-19 and OSHA recordkeeping

Many employers have questions about OSHA’s recordkeeping requirements – and the criteria for recordability – regarding COVID-19.

This is especially true when trying to determine whether a case is work-related.

Under the agency’s recordkeeping requirements, COVID-19 is a recordable illness, which means employers are responsible for recording cases of COVID-19 if the case:

1. Is confirmed to be COVID-19.
2. Is work-related, as defined by 1904.5.
3. Involves one or more of the general recording criteria set forth in 1904.7.

First, the case must be a confirmed as COVID-19. This means the employee must test positive using one of the testing methods approved by the Food and Drug Administration.

Next, the case must be work-related, as defined by 1904.5. According to the regulation, “work-related” means that an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a preexisting injury or illness. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception in 1904.5(b)(2) specifically applies (see 1904.5).

OSHA defines the work environment as “the establishment and other locations where one or more employees are working or are present as a condition of their employment. The work environment includes not only physical locations, but also the equipment or materials used by the employee during the course of his or her work.”

Lastly, the case involves one or more of the general recording criteria set forth in 1904.7, as follows:

“You must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, 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. You must also consider a case to meet the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.”