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Is COVID-19 a Recordable Illness Under 29 CFR 1904.7?

Posted on 4/13/2020 by Roger Marks

Update 10/12/20: OSHA added FAQ questions to its COVID-19 page to clarify the reporting requirements for work-related cases of COVID-19 that result in hospitalization. To be reportable, the guidance reads, "an in-patient hospitalization due to COVID-19 must occur within 24 hours of an exposure to SARS-CoV-2 at work."  

Update 5/26/20: OSHA updated enforcement guidance specific to recording workplace cases of COVID-19. OSHA makes it clear that they will enforce the recordkeeping requirements for workplace illnesses and injuries for all employers. The guidance includes a discussion of how employers can determine the “work-relatedness” of a novel coronavirus case. This rescinds OSHA's previous guidance related to recording cases of COVID-19.

On April 10, 2020, OSHA issued interim guidance related to recording cases of COVID-19 that occur in the workplace. Normally, illnesses contracted in the workplace are recordable if they are new cases and result in medical treatment beyond first aid, days away from work, or other criteria in 29 CFR 1904.7.

Therefore, OSHA’s interim guidance for illness recordkeeping relaxes the recordkeeping requirement for COVID-19 cases for all employers except those in healthcare industry, emergency response organizations, and correctional institutions.

For these employers, OSHA will only enforce its recordkeeping requirements when two conditions are met:
  1. There is objective evidence that a COVID-19 case may be work related; and
  2. The evidence was reasonably available to the employer.
Employers in the healthcare industry, emergency response organizations (e.g., EMTs, firefighters, police), and correctional institutions must continue to make work-relatedness determinations as laid out in 29 CFR Part 1904.

OSHA issued this guidance because employers may struggle to determine whether a new COVID-19 case is “work-related” for the purpose of recordkeeping. In other words, it might be hard to tell if the employee was exposed to COVID-19 at work.  

Read the full Interim Guidance here. 

OSHA Rules for Injury and Illness Recordkeeping

Employers in non-exempt industries with ten or more full-time-equivalent employees (including temporary workers and contractors) must record each fatality, injury, or illness that:
  1. Is work-related,
  2. Is a new case, and
  3. Results in death; days away from work, on restricted work, or transferred from usual work (DART); medical treatment beyond first aid, loss of consciousness; or a "significant injury or illness" as diagnosed by medical professional.
In 2016, OSHA finalized a rule to require employers to make annual, electronic reports of injury and illness data from OSHA Forms 300, 300A, and/or 301.

For more details about how to record work-related injuries, check out our whitepaper 9 Exceptions to OSHA Injury Reporting.

Related Reading: Fainting at the Sight of Blood—Is It Recordable?

On-demand OSHA Safety Training

Find training for healthcare personnel, general industry employees, and emergency responders in Lion's OSHA safety training course catalog. The catalog includes courses that provide required training for frontline employees fighting the COVID-19 outbreak, including:  Browse all OSHA safety courses at Lion.com/OSHA.

Tags: 29 CFR 1904.7, coronavirus, covid19, injury reporting and recordkeeping, osha

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