COVID-19: A Potential OSHA Recordable Illness
Recently published guidance from OSHA clarifies that workplace-contracted COVID-19 can be a recordable illness. It's important to have a plan in place.
Updated 5/22/20
Recently published guidance from OSHA clarifies that workplace-contracted COVID-19 can be a recordable illness. That is, a recordable if it was contracted as a result of work duties.
Illnesses such as the flu and colds have always been, and continue to be, exempt from recordable illnesses recordkeeping. However, COVID-19 is NOT exempt from being a recordable, even though it contains some of the same symptoms as the flu and cold.
⚡ TL;DR: Work-contracted COVID-19 is OSHA recordable if confirmed, meets recording criteria (medical treatment, hospitalization, or days away), and is work-related under 29 CFR 1904.5. Employers must investigate work-relatedness and maintain recordkeeping documentation. Failure to record can result in OSHA citations.
When COVID is Recordable
Use the following guidelines when determining if a case of COVID 19 is a recordable illness:
- Is confirmed as a coronavirus illness,
- Falls under one or more of the typical recording criteria such as medical treatment beyond first aid, hospitalization, or days away from work, and
- Is work related as defined by 29 CFR 1904.5.
Determining if it’s work related will take some investigation on your part as there’s a possibility that exposures can occur outside of work as well. OSHA expects employers to make reasonable efforts, based on the evidence available to make that determination.
⚠️ What’s at stake: Failure to properly record work-related COVID-19 illnesses can result in OSHA citations carrying penalties of $5,000–$15,000 per violation. Facilities with multiple unrecorded cases face accumulating violations and potential retaliation claims from employees.
Have a Plan
Some workplaces and worker tasks are considered to have a higher risk for employee exposure. Most workplaces will have a low exposure risk. Those in healthcare, death care, airline, border protection, solid waste management and wastewater treatment are considered to be in the high risk category. Workers who are required to work within 6 feet of each other would fall in the medium risk exposure level because the virus is spread through person-to-person droplet contact within that 6-foot range.
As a result, OSHA says it is important for workplaces to take measures to prevent the spread of COVID-19 and have a plan for dealing with it.
Hierarchy of Controls
OSHA’s guide contains ideas for identifying and isolating sick people, where appropriate. OSHA also draws on the Hierarchy of Controls, just as it does for all other safety concerns. For example:
Engineering Controls
- High-efficiency air filters
- Increased ventilation rates
- Negative pressure ventilation in areas where aerosols are generated
Administrative Controls
- Encouraging sick workers to stay home
- Virtual or teleconferenced meetings rather than face-to-face
- Alternating days or extra shifts to reduce the number of employees in the building, increasing work distances
- Discontinuing non-essential travel
- Emergency communication plans
- Worker training
Safe Work Practices
- Promote personal hygiene with tissues, no-touch trash cans, hand soap, alcohol rubs and wipes, disinfectants and disposable towels
- Required regular hand washing or alcohol hand rubs, especially after removing PPE
- Post handwashing signs in restrooms
PPE
- Select based on hazard to the worker
- Ensure proper fit and refit
- Consistent and proper wear
- Regular inspections
- Regular cleaning, maintenance and repair
- Proper storage and disposal
Does your facility have documented COVID-19 exposure controls and illness investigation procedures? Are OSHA 301 forms current and properly completed? iSi Environmental helps facilities establish compliant illness reporting systems. Get a recordkeeping audit →
💰 The cost of non-compliance: OSHA fines for failure to record work-related COVID-19 illnesses range from $5,000–$15,000 per citation. Facilities cited multiple times can face combined penalties exceeding $100,000, plus costs of correcting underlying exposure control gaps.
Frequently Asked Questions
Q: When is work-contracted COVID-19 considered an OSHA recordable illness?
Work-contracted COVID-19 is recordable if it meets three criteria: (1) confirmed as a coronavirus illness, (2) falls under typical recording criteria such as medical treatment beyond first aid, hospitalization, or days away from work, and (3) is work-related under 29 CFR 1904.5. Employers must make reasonable efforts to determine work-relatedness based on available evidence. Unlike common flu and colds, COVID-19 is not exempt from recordkeeping requirements. iSi Environmental helps employers document and record COVID-19 cases correctly to meet OSHA requirements.
Q: What industries and jobs are considered high-risk for COVID-19 exposure under OSHA guidelines?
OSHA identifies healthcare workers, morticians, airline personnel, border protection officers, solid waste management workers, and wastewater treatment workers as high-risk exposure occupations. Workers required to work within 6 feet of each other face medium-risk exposure because COVID-19 spreads through person-to-person droplet contact within 6 feet. Most office workplaces are considered low-risk. Facilities must assess their specific exposure risk and implement appropriate prevention measures. iSi Environmental helps facilities evaluate COVID-19 exposure risk and implement hierarchy of controls.
Q: What engineering controls does OSHA recommend for COVID-19 prevention?
OSHA’s engineering controls include high-efficiency air filters, increased ventilation rates, and negative pressure ventilation in areas where aerosols are generated (such as medical or laboratory spaces). These controls reduce the concentration of infectious particles in the air. Engineering controls are the most effective approach in the hierarchy of controls and should be implemented before relying solely on administrative controls or PPE. iSi Environmental helps facilities assess ventilation systems and recommend engineering improvements for COVID-19 prevention.
Q: What are OSHA’s requirements for PPE during COVID-19 pandemic response?
OSHA requires PPE to be selected based on the worker’s actual hazard exposure, properly fitted and refitted, worn consistently and correctly, inspected regularly, cleaned/maintained/repaired as appropriate, and properly stored and disposed. Healthcare and high-risk workers may require respirators, while lower-risk workers may need masks and eye protection. Training on proper PPE use is mandatory. iSi Environmental helps facilities implement compliant PPE programs including fit-testing and training.
Every satisfactory illness recording program starts with knowing your exposure risks and investigation procedures. iSi Environmental helps industrial and manufacturing facilities across Kansas, Oklahoma, and Texas implement compliant COVID-19 exposure controls and recordkeeping systems. Schedule an illness documentation audit →
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