On April 10, 2020 the Occupational Safety and Health Administration released a memorandum detailing enforcement guidance for recording cases of Coronavirus disease 2019 (COVID-19). The memo provides interim guidance to Compliance Safety and Health Officers (CSHOs) for enforcing the requirements of 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses. While expected to be time-limited to the current public health crisis, this guidance took effect on April 10 and will remain in effect until further notice.

The purpose of this rule is to require employers to record and report work-related fatalities, injuries, and illnesses – including COVID-19. Employers are responsible for recording cases of COVID-19, if:

      • The case is a confirmed case of COVID-19, as defined by Centers for Disease Control and Prevention (CDC) [1] – an individual with at least one respiratory specimen that tested positive for SARS-CoV-2, the virus that causes COVID-19;
      • The case is work-related as defined by 29 CFR § 1904.5 [2] –if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness; and
      • The case involves one or more of the general recording criteria set forth in 29 CFR § 1904.7 [3] – if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. You must also consider a case to meet the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness

According to the memo, “employers of workers in the healthcare industry, emergency response organizations (e.g., emergency medical, firefighting, and law enforcement services), and correctional institutions must continue to make work-relatedness determinations pursuant to 29 CFR § 1904.”

COVID-19 is a respiratory illness and should be coded as such on the OSHA Form 300.

Please check OSHA’s webpage at www.osha.gov/coronavirus for updates.


Blog by Eleisha Wilkes, RN, RAC-CTA, Proactive Medical Review

Learn more about Eleisha and the rest of the Proactive team.