OSHA Recordkeeping
The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) has adopted policies for enforcing OSHA's requirements for coronavirus as schools reopen in states throughout the country.
As states begin reopening their schools, OSHA has issued two primary enforcement policies to ensure employers are taking action to protect their employees.
- OSHA is conducting in-person inspections at all types of workplaces. OSHA staff will prioritize COVID-19 inspections and will use all enforcement tools as OSHA has historically done.
- Under OSHA's recordkeeping requirements, coronavirus is a recordable illness, and school administrators are responsible for recording cases of the coronavirus, if the case:
- Is confirmed as a coronavirus illness;
- Is proven to be 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.
OSHA will enforce the recordkeeping requirements of 29 CFR 1904 for employee coronavirus illnesses for all employers. The Emergency Operation Plan (EOP) should address recording coronavirus illnesses.
Given the nature of the disease and community spread in many instances, it remains difficult to determine whether a coronavirus illness is work-related, especially when an employee has experienced potential exposure both in and out of the workplace. OSHA's guidance emphasizes that employers must make reasonable efforts to ascertain whether a particular case of coronavirus is work-related.
For more information, see OSHA's COVID-19 standards webpage and OSHA's COVID-19 Frequently Asked Questions.
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2-9. What criteria must be met to satisfy OSHA's recordkeeping requirements for recording cases of coronavirus?
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