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Update 03/2020 ‐ OSHA Deems COVID-19 a Recordable Illness

COVID-19 continues to dominate the headlines and change our work and personal routines. This dynamic situation is creating questions, and some that are coming up more frequently center on the OSHA 300 log: Are COVID-19 cases recordable illnesses? Do the assigned work tasks of the employee make a difference? How do you determine where the employee was exposed? OSHA provided some very early and initial guidance that erred on the side of recording COVID-19 cases. OSHA has since issued a clarification of that advice.

Federal OSHA’s standard on recording and reporting occupational injuries and illness, 29 CFR 1904.5, exempts the common cold and flu from being an OSHA recordable case. That means that even if someone believes an exposure at work caused them to become infected with either, that case should not be entered on the OSHA 300 log. However, COVID-19 is not the seasonal flu and OSHA has deemed those recordable cases as long as they meet these three criteria:

  1. The case is a confirmed case of COVID-19 (see on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19);
  2. The case is work-related, as defined by opens in a new window29 CFR 1904.5; and
  3. The case involves one or more of the general recording criteria set forth in opens in a new window29 CFR 1904.7 (e.g. medical treatment beyond first aid, days away from work)

Below are selected resources that can assist with recordkeeping and provide information to help prevent the spread of the virus through your workforce.

OSHA & CDC Resources

Summary of OSHA standards applicable to COVID-19, including the requirement to record these illnesses on the OSHA 300 log:
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Guidance on Preparing Workplaces for COVID-19
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CDC’s homepage for COVID-19
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Related Articles

Parker, Smith & Feek article on preparing and responding to the spread of COVID-19
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For assistance or information regarding other impacts this pandemic may have on your business, contact your Parker, Smith & Feek account team.


This article is provided for informational purposes only and is not intended to provide legal or actuarial advice. The issues and analyses presented in this article should be reviewed with outside counsel before serving as the basis of any legal or other decision.

The views and opinions expressed within are those of the author(s) and do not necessarily reflect the official policy or position of Parker, Smith & Feek. While every effort has been taken in compiling this information to ensure that its contents are totally accurate, neither the publisher nor the author can accept liability for any inaccuracies or changed circumstances of any information herein or for the consequences of any reliance placed upon it.

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