OSHA COVID-19 Recordkeeping Guidance Updates

Due to the volatile nature of 2020 and the emergence of the COVID 19 epidemic, the Occupational Safety and Health Administration released updated record-keeping measures that address COVID 19 cases in the workplace. The update released on the 19th of May takes the place of past released safety measures that address the record-keeping and safety of employees within the workplace against virus-related hazards, such as the contracting and spread of the COVID 19 virus.

While the following compliance requirements often relate to larger companies within high risks industries it would be highly beneficial for all companies to adopt some of the practices stated to ensure health and safety. It must be noted that small enterprises, within low risks industries such as legal or accounting services, with less than 10 employees are free from the obligation of having to maintain an OSHA 300 logbook. These companies are only required to report work-related illnesses, severe injuries, and deaths. As with medium enterprises, it is encouraged that smaller businesses adhere to strict health and safety record keeping measures in order to do their part during the current epidemic.

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Record keeping guidelines

OSHA recordkeeping standards now classify COVID19 as a recordable illness and require employers to record these cases within their injuries and illnesses log book in order to remain compliant. The updated OSHA 300 logging requirements that must be met in order in order for a company to record employee injuries and illnesses are as follows:

• An employee’s COVID19 diagnosis has been confirmed according to the definition set out by the Center for Disease Control and Prevention, confirmed cases require laboratory evidence.
• The illness or injury must be work-related. According to OSHA, this means that the recordable illness or injury must be due to an incident or exposure to a virus within the workplace.
• If the case meets the general requirements for recording such as injuries or illnesses that result in death, loss of consciousness, time off work, or considerable medical assistance that exceeds first aid.

OSHA assessment criteria

In order to be certain that businesses comply with their regulations, OSHA may exercise the right to review certain processes undertaken by a company.

The processes conducted by businesses that may be reviewed by OSHA are the following:

• The extent of the investigation.

This refers to the processes a company takes to understand whether the illness or injury is work-related. While it may be difficult to determine whether an employee was exposed to COVID-19 in the workplace it is advisable for businesses to take the following steps in order to gain insight into the work-relatedness of the incident. With the employees about they could have contracted the virus, getting an understanding of the employee’s activities outside of their working hours, and reviewing the worksite for possible exposure should be conducted.

• The review of the available evidence

The business should reasonably review all the possible forms of evidence that are relevant to the work-relatedness of the incident. Only evidence collected after one inquiry is not deemed to be reasonable as evidence found, later on, should be included.

• The review of the evidence stating the virus was contracted at work.

During this process, businesses should review the evidence of the virus being contracted at work. Sources of virus exposure must be considered as well as alternative explanations.

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OSHA recordkeeping during COVID-19

Businesses who gain a clear understanding of OSHA’s assessment criteria will be able to accurately complete injury and illness record logs and ensure error-free record-keeping practices.

It is important to note that while a business might take all the steps required to ensure a reasonable and thorough investigation has taken place it is still possible for the source to remain unknown. This means that the business has not violated any OSHA standards as an undetermined case cannot be recorded. However, if an employer knowingly violates OSHA standards and refuses to log an employee who succumbs to COVID 19 within the workplace then the business can receive a financial penalty, this penalty will increase for every year in which the record remains inaccurate. Implementing an occupational health and safety application assists in maintaining accurate record logging, the mobile and cloud-based software solutions available provide functions that can allow worksites to streamline the reporting of evidence and accurately record the incidents and injuries within one platform ensuring efficient record keeping and OSHA compliance.

Safeguarding Worksites

Moving forward OSHA has suggested that all businesses implement a safety program to address infectious diseases. Regularly training and updating workers on the latest OSHA standards to ensure best practices will be highly beneficial in remaining compliant and creating a culture of employee safety. Encouraging employees to adopt safe working habits such as wearing personal protective equipment at all times and washing their hands can yield great results for companies who are trying to minimize their employee’s risks. While many organizations may view OSHA to be an annoyance, understanding their requirements and adopting their suggestions would be the responsible choice to make.