Is Covid-19 a Recordable Illness to OSHA? - Worksite Medical
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**Updated April 16, 2020

In a new enforcement memo issued April 10, 2020, OSHA recognized the difficulty for employers to determine if an employee contracted coronavirus at work.

The administration also emphasized the need for employers to “focus their response efforts on implementing good hygiene practices in their workplaces, and otherwise mitigating COVID-19’s effects, rather than on making difficult work-relatedness decisions in circumstances where there is community transmission.”

Therefore, until further notice, OSHA will not enforce the recordkeeping requirements outlined in the article below for recordable illness for the majority of employers.

There are, however, two exceptions to this:

  1. Objective evidence exists that a coronavirus case may be work-related (e.g., cases developing among workers who work closely together without another explanation; and
  2. Evidence was reasonably available to the employer (e.g., employee shared information with their employer, or employer learns information in the ordinary course of managing its business and employees.


Employers must continue to make work-relatedness determinations, per the article below, if they employ workers in the healthcare industry, emergency response organizations (e.g., emergency medical, firefighting, and law enforcement services), and correctional institutions.

COVID-19 news, questions, and confusion — caused by the ongoing pandemic of the novel coronavirus —  are spreading almost as rapidly as the virus itself.

It comes as no surprise that many employers wonder whether or not they need to report cases of COVID-19 as recordable illnesses. The confusion is understandable, given that incidents of employees contracting common colds and the flu in the workplace are not recordable. But, other infectious diseases, such as tuberculosis and hepatitis C, must be evaluated by employers to determine the need to report them like other injuries and illnesses.

OSHA recently issued guidance saying that COVID-19 can be a recordable illness if all the following points are met:

  • The case is a confirmed case of COVID-19; and
  • the case is work-related; and
  • the case involves one or more of the general recording criteria.


How can you be sure an employee’s COVID-19 case is work-related?


As defined by OSHA 29 CFR 1904.5, an employer must decide “whether it is more likely than not that work events or exposures were a cause of the injury or illness.”

When an employer has trouble deciding “whether the precipitating event or exposure occurred in the work environment or occurred away from work,” OSHA says that employer “must evaluate the employee’s work duties and environment to decide.” 


Related: OSHA Tells Employers to Prepare For Coronavirus Outbreak


It is possible asymptomatic COVID-19 employees may have reported for work, and unintentionally transmitted the coronavirus to other employees. However, unless one or more of the following general recording criteria has occurred, the illness is not recordable:

  • Death
  • Days away from work
  • Restricted work or transfer to another job
  • Medical treatment beyond first aid
  • Loss of consciousness
  • A significant injury or illness diagnosed by a physician or other licensed health care professional


What About Different Illnesses and Injuries?


Is it easy to tell what is recordable on OSHA 300 and 301 Forms?

Unfortunately, this question is only easy to answer if a work-related accident resulted in an amputation, fracture, burn, or another type of traumatic injury. Additionally, the same rules apply if an employee develops an illness following exposure to a toxic substance, such as silica, lead, or cadmium.

So, what about illnesses and injuries that may be noticeable at work, but are related to a combination of occupational and personal factors?


Related: Mobile Coronavirus Symptom Screening Now Available


For example, an employee’s pre-existing medical condition, such as asthma or COPD, worsens when exposed to dust or mold. Or, perhaps employees with back, knee, or shoulder injuries experience additional pain while lifting heavy objects or performing repetitive tasks.

With nine exceptions, OSHA’s illness and injury reporting rule requires that “employers consider an injury or illness to be ‘work-related’ if an event or exposure in the work environment is:

  • either caused or contributed to the resulting condition; or
  • significantly aggravated a pre-existing injury or illness.”


Significant Workplace Aggravation of a Pre-existing Condition


According to OSHA, a pre-existing injury or illness must be one caused entirely by non-occupational factors, and the amount of aggravation of the injury or illness that work contributes must be “significant.”

Preexisting means an injury or illness, “resulted solely from a non-work-related event, or exposure that occurred outside the work environment.”

The rule defines aggravation as significant “if the contribution of the aggravation at work is such that it results in tangible consequences that go beyond those that the worker would have experienced as a result of the preexisting injury or illness alone, absent the aggravating effects of the workplace. The tangible consequences include:

  • Death
  • Loss of consciousness
  • One or more days away from work, or days of restricted work, or days of job transfer
  • Medical treatment in a case where no medical treatment was needed for the injury or illness before the workplace event or exposure or a change in medical treatment was necessitated by the workplace event or exposure.


Deciding on reporting a recordable illness is not as easy as reporting workplace injuries. But, reporting recordable illnesses is just as important as reporting recordable injuries.


About Worksite Medical

In most cases, OSHA requires medical surveillance testing, and at no cost to employees.

Worksite Medical makes that program easier with mobile medical testing.

We conduct on-site respirator fit tests, as well as pulmonary function test and heavy metal lab work, right on your job site. We also keep accurate, easy-to-access medical records for your convenience. You’ll keep your employees at work, and stay ahead of OSHA inspections.

With Worksite Medical, a mobile medical testing unit — we can bring all the resources of a lab to you. Our certified lab technicians can perform both qualitative and quantitative respirator tests to ensure a perfect fit.

Protect your team and your workplace now with Worksite Medical. Not sure what you need? Try our medical testing wizard here.

Give us a call at 1-844-622-8633, or complete the form below to schedule an on-site visit or to get your free quote!

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