This memorandum provides updated interim guidance to Compliance Safety and Health Officers (CSHOs) for enforcing the requirements of 29 CFR Part 1904 with respect to the recording of occupational illnesses, specifically cases of COVID-19. On May 26, 2020, the previous memorandum on this topic[1] will be rescinded, and this new memorandum will go into and remain in effect until further notice. This guidance is intended to be time-limited to the current COVID-19 public health crisis. Please frequently check OSHA’s webpage at www.osha.gov/coronavirus for updates.
Under OSHA’s recordkeeping requirements, COVID-19 is a recordable illness, and thus employers are responsible for recording cases of COVID-19, if:
- The case is a confirmed case of COVID-19, as defined by the Centers for Disease Control and Prevention (CDC);[2]
- The case is work-related as defined by 29 CFR § 1904.5;[3] and
- The case involves one or more of the general recording criteria set forth in 29 CFR § 1904.7.[4]
Here is a link to a checklist for reporting occupational illness created by Dinsmore.