Posted by Thelma Marshall, Product Director, April 7, 2020

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If there’s a suspected case of COVID-19 in your facility, OSHA expects a report to be filed. Unlike other viruses, incidents of Coronavirus has different guidelines than those set for the flu or the common cold.

Reporting standards created by OSHA can be confusing. But, keep in mind that while the “common cold and flu” are exempt from OSHA’s recording requirements, which means they don’t have to be recorded on an employer’s OSHA 300 log, how OSHA views COVID-19 cases has changed over the last few weeks.

OSHA has taken the position that COVID-19 should be treated, for recording purposes, like several other serious or contagious illnesses. For example, tuberculosis, brucellosis, hepatitis A, or plague must be recorded as work-related if the employee is infected at work.  That is the reporting criteria you need to remember— if it was caught while the employee was at work.

OSHA states its position on recordkeeping in a section of its website called, “OSHA Injury and Illness Recordkeeping and Reporting Requirements.” But, the obvious question for most employers is what to do if it isn’t obvious if exposure occurred in the work environment or someplace else.

Tips in determining exposure

While there isn’t specific guidance on making this determination, is it wise to follow good-faith recordkeeping determinations regarding just like you would use for an injury or illness. Employers must decide if, and how, a case should be recorded, and base it on all indicating facts they can gather.

For example, has the infected employee recently traveled? Do they have a family member who has been sick with similar symptoms or has been diagnosed? Has anyone else at work had symptoms, perhaps mild enough that testing wasn’t even considered? Do some employees work in close proximity to each other?

By gathering a few facts, a good-faith determination can be made as to whether the employee likely caught the virus while working or if there were increased risk factors outside of work.

Recording workplace exposures to COVID-19

OSHA recordkeeping requirements at 29 CFR Part 1904 mandate covered employers record certain work-related injuries and illnesses on their OSHA 300 log. COVID-19 can be a recordable illness if a worker is infected as a result of performing their work-related duties.

But employers are only responsible for recording cases of COVID-19 if all of the following are met:
  1. The case is a confirmed case of COVID-19 (see CDC information on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19);
  2. The case is work-related, as defined by 29 CFR 1904.5; and
  3. The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7 (e.g. medical treatment beyond first-aid, days away from work).

Remember, that documentation is crucial when it comes to safety, seeking answers and filing a report with OSHA. An advanced telematics system provides real-time monitoring and documentation on all the moving parts of an organization.

 

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