Guidance on when to report COVID-19 infections in OSHA 300 log

The Occupational Safety and Health Administration (OSHA) requires most employers to keep an OSHA 300 log and complete an OSHA Form 301 when an employee suffers a “work-related” recordable illness or injury. You must then post an annual summary of the log. You’re also required to notify the agency directly if an employee death, hospitalization, amputation, or loss of an eye is work-related (fatalities must be reported within eight hours and the remainder within 24 hours). Under the Occupational Safety and Health (OSH) Act regulations, you aren’t required to report a common cold or even the flu on the OSHA 300 log. So, what about the novel coronavirus?

When coronavirus infection must be reported

According to OSHA’s recent new guidance, COVID-19 isn’t a cold or the flu, and you must report it on your OSHA 300 log when:

• The incident is a confirmed case of COVID-19, as defined by the U.S. Centers for Disease Control and Prevention (CDC);
• It’s work-related; and
• It involves one or more of the general recording criteria set forth in the OSH Act’s applicable regulations, such as days away from work or medical treatment beyond first aid.

Under the Act’s long-standing regulations, employers must consider an injury or illness to be work-related if an event or exposure in the work environment caused or contributed to the resulting condition or significantly aggravated a preexisting injury or illness.

How to determine COVID-19’s work-relatedness