Is COVID-19 a Recordable Illness?

Since COVID-19 has impacted the U.S. from the beginning of the year, the growth of the illness has fluctuated and widely exploded. With official recordkeeping stats claiming millions of COVID cases, nationwide industries and the entirety of the American workforce have been especially impacted.

Is COVID-19 a recordable illness? This is a question to be determined by looking at the facts and standards set by the Occupational Safety and Health Administration (OSHA). OSHA has declared directives about the state of the virus for employers’ understanding. Let’s break it down here.

Reportable Versus Recordable for OSHA

OSHA recordkeeping requirements, codified at 29 C.F.R. Part 1904, mandates that covered employers record certain work-related injuries and illnesses sustained by employees on their OSHA 300 log. OSHA regulations also require that employers report: 1. work-related in-patient hospitalization, amputation, or loss of an eye within 24 hours, and 2. all work-related fatalities within eight hours.

Is COVID-19 a recordable illness? 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 of the following are true: 1. The case is a confirmed case 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).

The Occupational Safety and Health Act’s (the OSH Act) recordkeeping and reporting requirements apply to work-related illnesses that include respiratory illnesses. While the OSH Act regulations explicitly exempt the common cold and the seasonal flu from recording and reporting requirements, OSHA has declared that confirmed cases of COVID-19, despite similarities with influenza, are not exempt. COVID-19 is therefore an illness within the meaning of the OSH Act regulations.

What Constitutes a “Confirmed Case” of COVID-19 For OSHA Recording?

OSHA directs employers to follow the Centers for Disease Control and Prevention (CDC) guidelines which define a “confirmed case.” This definition distinguishes between patients who are a: person under investigation (PUI) for suspected COVID-19; a presumptive positive; and a laboratory-confirmed case. For purposes of OSHA’s recording requirements, only those employees who have a laboratory-confirmed case are recordable.

Is the confirmed case of COVID-19 “work-related?” See OSHA’s determination of work-relatedness for guidance on determining whether an injury or illness is work-related. Then, see OSHA’s General recording criteria for guidance of determining whether an injury or illness meets the recording criteria.

Are All Recordable Illnesses Reportable?

No, only COVID-19 employee work-related illnesses that result in an inpatient hospitalization or death are reportable to OSHA. In-patient COVID-19 hospitalizations must be reported to OSHA within 24 hours, and work-related COVID-19 fatalities must be reported to OSHA within eight hours. A case meets OSHA’s recording criteria if it results in: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a physician or other licensed healthcare professional.

Medical OSHA Compliance

The above knowledge is vital for all establishments that are required to maintain injury and illness records at work—especially those in the healthcare industry. An employer’s compliance with OSHA rules is all about creating and sustaining a safe and healthy work environment for all employees.

For those in the healthcare field, having an OSHA program manual for medical facilities can come in handy. Gamma Compliance Solutions has the necessary materials to help with all your documentation needs and further education on recordkeeping requirements.