General Recordkeeping Criteria in the Age of COVID-19 — Occupational Health & Safety


General Recordkeeping Criteria in the Age of COVID-19

By Lisa Neuberger, EHS Editor at J. J. Keller & Associates, Inc.

The COVID-19 pandemic is changing the way we do business in this country. Workers who are able to are now working from home, and workers who are in construction or manufacturing are practicing social distancing on the job. Healthcare workers, social workers, and others who have contact with the public must take extra precautions to protect themselves from exposures to the coronavirus. With these changes come questions about how to record work-related cases of COVID-19 and whether to report to OSHA deaths or hospitalizations related to the illness.

Read on to learn what OSHA has to say about the recordability of COVID-19 in the workplace along with the agency’s injury and illness recordkeeping and reporting regulations in 29 CFR Part 1904.

ARE THERE ANY ADDITIONAL CRITERIA TO MEET FOR A CASE OF COVID-19 TO BE RECORDABLE?

Yes. OSHA says that for it to be recordable, a new case of COVID-19 must be work-related, confirmed by a laboratory test, and meet one or more of the recording criteria.

WHAT DOES OSHA MEAN BY “CONFIRMED”?

A confirmed case of COVID-19 means an individual with at least one respiratory specimen that tested positive for SARS-CoV-2, the virus that causes COVID-19.

IS AN EXPOSURE AUTOMATICALLY RECORDABLE?

No. An employee exposure to the illness in the workplace is not automatically recordable. The exposure must result in signs or symptoms of the disease and be confirmed by a laboratory test. In addition, it must meet one or more of the general recording criteria.

WHAT ARE THE GENERAL RECORDKEEPING CRITERIA?

The general recordkeeping criteria are listed in order of seriousness in §1904.7 and include:

  • Death
  • Days away from work
  • Restricted work activity or job transfer
  • Medical treatment beyond first aid
  • Loss of consciousness
  • Significant injury diagnosed by a physician or other licensed health care professional



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