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April 17, 2020
As the COVID-19 pandemic continues, adjustments are being made by everyone, and that even includes Federal OSHA. As we previously shared, OSHA had determined that some COVID-19 cases are recordable illnesses which must be entered on an employer’s OSHA 300 log. They have once again provided some clarification on this requirement, which reduces that burden on most employers. On April 10, 2020, OSHA issued a new memo addressing their current stance, excerpt below:
Employers of workers in the healthcare industry, emergency response organizations (e.g., emergency medical, firefighting, and law enforcement services), and correctional institutions must continue to make work-relatedness determinations pursuant to 29 CFR § 1904. Until further notice, however, OSHA will not enforce 29 CFR § 1904 to require other employers to make the same work-relatedness determinations, except where:
This clarification from Federal OSHA should simplify the OSHA 300 log recordkeeping process during this pandemic for most employers. Below is a link to the full memo from OSHA, as well as additional resources to assist with preventing infection with COVID-19.
Federal OSHA Enforcement Memo:
Summary of OSHA standards applicable to COVID-19, including the requirement to record these illnesses on the OSHA 300 log:
Guidance on Preparing Workplaces for COVID-19
CDC’s homepage for COVID-19
For assistance or information regarding other impacts this pandemic may have on your business, contact your Parker, Smith & Feek account team.
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.