The news about Coronavirus is changing daily and adapting to these changes is something all jobsites will need to be ready for. If you are here, you are most likely wondering how COVID-19 will affect your OSHA recordkeeping. Hopefully this guide will help you understand how to keep in OSHA compliance during these trying times.
As you probably already know, companies with 10 or more employees at any point in the year in a high-risk industry are required to keep OSHA 300 logs for their job site. OSHA recordkeeping requirements at 29 CFR Part 1904 mandate covered employers record certain work-related injuries and illnesses on their OSHA 300 log.
Specific OSHA rules on recordkeeping can be found here:
So, do you need to report on your OSHA 300 logs if an employee contracted COVID-19 from your work site?
According to the OSHA website, COVID-19 can be a recordable illness if a worker is infected as a result of performing their work-related duties. However, employers are only responsible for recording cases of COVID-19 if ALL the following are met:
- 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).
- The case is work-related, as defined by 29 CFR 1904.5
- 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).
More information can be found at: https://www.osha.gov/SLTC/covid-19/standards.html.
Recommendations from the CDC say that employees can come out of isolation if they meet all three of these requirements or have a doctor’s note that they can return to work.
- You have had no fever for at least 72 hours (that is three full days of no fever without the use medicine that reduces fevers)
- Other symptoms have improved (for example, when your cough or shortness of breath have improved)
- At least 7 days have passed since your symptoms first appeared
You can find all CDC related information here https://www.cdc.gov/coronavirus/2019-ncov/if-you-are-sick/steps-when-sick.html
I recorded the illness on my 300 logs now what? Do I need to report it directly to OSHA?
No, unless it results in a work-related fatality or if they are hospitalized due to contracting the disease performing work related duties.
We also recommend keeping a personal record of employees who contract the Coronavirus for your site safety. If you can track where the illness started, you are able to help the people that have come into contact with a sick person avoid contracting the disease themselves. This will help high risk people from contracting Coronavirus and help slow the spread for all employees in the workplace.
We know during this difficult time that workers may lose focus and get distracted from their normal work tasks. This could have the potential to increase workplace accidents and injuries. Because of that potential, we are urging all our clients to stay focused on the job so that everyone can return home safely at the end of the day. Site and crew supervision will continue to be very important to assist with maintaining workers safety.
If you have any questions we did not address or site specific questions, please feel free to email us at firstname.lastname@example.org and we will be sure to reach out to you personally.