Recordkeeping memo widens net regarding COVID-19

Date Posted: 06/09/2020

Recordkeeping memo widens net regarding COVID-19Effective May 26, 2020, OSHA now requires ALL employers to record cases of COVID-19, if:

  • The case is confirmed as COVID-19, as defined by CDC;
  • The case is work-related per 29 CFR 1904.5;
  • The case involves one or more of the general recording criteria in 29 CFR 1904.7, such as medical treatment beyond first aid or days away from work;
  • The employer has 11 or more employees; and
  • The employer is not partially exempt from Part 1904.

Accordingly, until further notice, OSHA will enforce the recordkeeping requirements of 29 CFR 1904 for employee COVID-19 illnesses for all employers. OSHA instructs agency inspectors to consider the following when determining whether an employer has complied:

  • Reasonableness of the employer’s investigation into work-relatedness;
  • Evidence available to the employer; and
  • Evidence that the illness was contracted at work.

SOURCE: Revised Enforcement Guidance for Recording Cases of Coronavirus Disease 2019 (COVID-19); OSHA memo – 5/19/2020


How Safety Management Suite Can Help

Incident Center

Flexible and mobile-friendly, the INCIDENT CENTER within the J. J. Keller® SAFETY MANGAEMENT SUITE provides the tools needed to proactively manage OSHA recordkeeping and reporting requirements.

  • Track recordable and non-recordable incidents
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  • Utilize best-in-class OSHA training



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