Under OSHA’s recordkeeping requirements, COVID-19 is considered a recordable illness, and employers are responsible for reporting cases of COVID-19 as workplace injuries and illnesses if the case:
- Is confirmed as a COVID-19 illness;
- Is work-related as defined by 29 CFR 1904.5; and
- Involves one or more of the general recording criteria in 29 CFR 1904.7, such as medical treatment beyond first aid or days away from work.
In areas where there is ongoing community transmission, many employers may have difficulty making determinations about whether workers who contracted COVID-19 did so due to exposures at work, making accurate injury and illness reporting difficult.
OSHA Won’t Enforce Recordkeeping Requirements
Until further notice, OSHA will not enforce its recordkeeping requirements to require these employers to make work-relatedness determinations for COVID-19 cases. Exceptions include: (1) Objective evidence that a COVID-19 case is work-related; and (2) Evidence was reasonably available to the employer. Employers of workers in healthcare, emergency response, and correctional institutions must continue to determine if an illness is work-related based on 29 CFR Part 1904.
OSHA believes this enforcement policy will provide certainty to the regulated community and help employers focus their response efforts on implementing good hygiene practices in their workplaces and otherwise mitigating COVID-19’s effects.
For further information and resources about the coronavirus disease, please visit OSHA’s COVID-19 webpage.