Posted by Thelma Marshall, VP of Solutions, April 28, 2020

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OSHA is easing some of their recordkeeping requirements due to the impact of COVID-19 on businesses. This is in response to concern that some employers may have difficulty determining if employees contracted COVID-19 through exposures at work or an outside source.

Normally, OSHA form 300 must be filed by employers to record an illness or work-related injury. This is standard if an employee has a confirmed illness that is work-related that results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness.

Under OSHA’s recordkeeping requirements, COVID-19 is a recordable illness, and employers are responsible for recording cases of COVID-19.  But, this is only required under certain criteria and conditions.

For example, when the case is a confirmed case of COVID-19, as defined by Centers for Disease Control and Prevention (CDC). In other words, there is an actual positive test result proving the virus is present. Also, the case is must be work-related – meaning it was contracted through or at work.

Reporting challenges

So, the requirement has gotten tricky. In locations where community transmission rates are accelerating, many warehouse and manufacturing employers can’t determine if workers testing positive to COVID-19 contracted it at work.

Because of this, OSHA is issued some enforcement discretion about reporting cases if there is uncertainty about how an employee contracted the virus. On April 10 OSHA issued a memorandum that remains in effect until further notice and intended to be time-limited to the current public health crisis. OSHA’s webpage at is posting updates as the situation evolves.

The World Health Organization (WHO) declared COVID-19 a global pandemic on March 14 and spread of the virus is a rapidly evolving issue. The CDC’s current criterion for diagnosis is at least one respiratory specimen that tested positive for SARS-CoV-2, the virus that causes COVID-19.

During 2019, OSHA focused much of their time on employer safety initiatives, training programs and injury reporting requirements, conducting 33,401 inspections—more inspections than in the previous years. The year 2020 will definitely not be the same as any other before it.

Focus on safety and hygienic measures

It is vital to continue to provide workers with up-to-date education and training on COVID-19 risk factors and protective behaviors (e.g., cough etiquette and care of PPE).

Guidelines from OSHA include

  • Deploy an infectious disease response plan to guide protective actions against COVID-19.
  • Stay abreast of guidance from federal, state, local, tribal, and/or territorial health agencies, and consider how to incorporate those recommendations and resources into workplace-specific plans.
  • Consider and address the level(s) of risk associated with various worksites and job tasks workers perform at those sites.
  • Look at individual risk factors (e.g., older employees; presence of chronic medical conditions, including immunocompromising conditions; pregnancy).
  • Determine controls necessary to address those risks.
  • Options for operating with a reduced workforce— including cross-training workers across different jobs in order to continue operations or deliver surge services.
  • Develop contingency plans for interrupted supply chains, delayed deliveries or a complete shift in production processes.

Putting workplace safety first in 2020 has an additional set of guideline. Your telematic system should make safety easier, providing insight that identifies risky behavior, training needs, and removes language barriers that impede safety.

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