OSHA Recordkeeping Requirements for COVID-19 Exposure at Work
We're starting to hear the question often:
Will contracting COVID-19 be considered an OSHA recordable?
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The answer isn't as black-and-white as we'd like it to be. Since Coronavirus Disease (COVID-19) is a disease caused by the newly emerged coronavirus SARS-CoV-2, there is no specific OSHA standard or directive covering the disease as of March 18, 2020. Unlike the common cold or the flu, there is also no direct exception in 1904.5(b)(2) that excludes COVID-19 from recordable cases.
COVID-19 can be a recordable illness if the worker is infected as a result of performing his or her work-related duties and all of the following criteria are met.
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Criteria 1: The case must be a laboratory-confirmed, positive COVID-19 diagnosis
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This seems straightforward, but it is important to note that the case must be confirmed by laboratory testing by the CDC. All persons under investigation (PUI) with at least one respiratory specimen that tested positive for COVID-19 by a local or state testing laboratory are considered Presumptive Positive until Laboratory Confirmed by a CDC testing Laboratory.
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Criteria 2: The case must be work-related
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From a basic level, an illness is considered work-related in the event that exposure in the work environment either caused or contributed to the resulting condition of the illness. The exposure must clearly be linked to a work-related event and not the result of a non-work-related event.
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Criteria 3: The case must meet the general recording criteria for OSHA
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OSHA 1904.7 outlines the details for general recording criteria for injuries and illnesses. Any COVID-19 diagnosis that is work-related must also result in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness to be considered recordable.
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The Bottom Line:
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There will be times when COVID-19 is contracted in a work-related event and will be recordable. These cases must be laboratory-confirmed, work-related, and meet the general recording criteria for OSHA.
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OSHA300 is here to help if you have any questions in recordkeeping and recording requirements related to COVID-19.
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