Update – New Changes on COVID-19 as an OSHA Recordable Illness

As of May 26, OSHA has once again implemented a different set of guidelines for recording COVID-19 cases on OSHA 300 injury and illness logs. They have broadened the scope to formally include all industries, and are essentially requiring an accident investigation be performed to help determine whether a COVID-19 case was contracted while in the workplace.

Under OSHA’s recordkeeping requirements, COVID-19 is a recordable illness, and thus employers are responsible for recording cases of COVID-19, if:

  • The case is a confirmed case of COVID-19, as defined by the Centers for Disease Control and Prevention (CDC);
  • The case is work-related as defined by 29 CFR § 1904.5; and
  • The case involves one or more of the general recording criteria set forth in 29 CFR § 1904.7.

For determining work-relatedness, OSHA has listed some steps to guide the investigation, which can be found in the second half of the memo. See the link below.

Federal OSHA enforcement memo:
https://www.osha.gov/memos/2020-05-19/revised-enforcement-guidance-recording-cases-coronavirus-disease-2019-covid-19

Summary of OSHA standards applicable to COVID-19, including the requirement to record these illnesses on the OSHA 300 log:
https://www.osha.gov/SLTC/covid-19/standards.html

Guidance on preparing workplaces for COVID-19:
https://www.osha.gov/Publications/OSHA3990.pdf

CDC’s homepage for COVID-19:
https://www.cdc.gov/coronavirus/2019-nCoV/index.html

For assistance or information regarding other impacts this pandemic may have on your business, contact your Parker, Smith & Feek account team.

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