OSHA throws a curveball on coronavirus illness recording

Just when you thought you had a clear picture of your responsibilities for recording COVID-19 illnesses on your injury logs, OSHA has thrown you a curveball: Now you have to conduct an analysis before determining whether an illness is recordable.

The policy change was spelled out in a recent enforcement memo sent to OSHA’s regional offices.

Under the new approach, you have to ask a worker who has contracted COVID-19 how the person thinks he or she got the disease.

Furthermore, you must talk to the person about how his or her job and personal activities might have led to exposure to the coronavirus. And you need to analyze the victim’s work environment to uncover potential exposure points.

According to the memo, an illness should be considered work related if
• several cases have been reported among people working closely together
• the illness was contracted shortly after exposure to a coworker or a customer with a confirmed diagnosis of COVID-19
• the victim’s job duties included frequent contact with the general public in a community with ongoing coronavirus transmission

In all three cases, you can defeat the assumption that the condition is job related if you can provide an alternative explanation as to how the person got the disease.

What it means to you: The steps you’re taking to protect workers from the coronavirus are now doing double duty. That’s because you can almost always avoid recording a COVID-19 illness on your injury log if there’s been no significant outbreak of the disease in your workplace.

(From the June 1, 2020, issue of OSHA Compliance News. To download the rest of the issue for free, please click here.)