Coronavirus Concerns: Recordable cases and respirators

February 25, 2020


The Coronavirus has brought to light many questions and concerns about how businesses may be affected by a wide-spread contagious disease. Our partners at JJ Keller have just released a reminder that OSHA’s injury and recordkeeping regulation provides an exemption from recording the common cold and flu, but the coronavirus is recordable if it results from a work-related exposure.

Read Keller’s article below for more about the recording:

If an employee contracts the coronavirus from a coworker or workplace exposure, OSHA has said that would be a recordable case on the 300 Log. To protect themselves or their coworkers, some employees might request to wear dust masks or surgical masks.

According to the Centers for Disease Control (CDC), the virus would most likely spread from person-to-person among close contacts (about 6 feet). Transmission is thought to occur mainly via droplets when an infected person coughs or sneezes, similar to how influenza spreads. It’s currently unclear if a person can get coronavirus by touching a surface or object that has the virus on it and then touching their own mouth, nose, or possibly their eyes.

Illness recordkeeping

Although the injury and illness recordkeeping regulation provides an exemption from recording the common cold and flu, the coronavirus is recordable if it results from a work-related exposure. Other contagious diseases such as tuberculosis, brucellosis, hepatitis A, or plague are also considered work-related cases if the employee is infected at work.

OSHA addresses tuberculosis (TB) at §1904.11 as a disease spread from person to person by airborne bacteria, so the provisions should translate to cases of coronavirus. Under that section, if an employee is occupationally exposed to anyone with a known case of active TB and develops an infection (diagnosed by a physician or licensed health care professional), you must record the case on the OSHA 300 Log by checking the “respiratory condition” column.

If you later learn that the disease was not caused by occupational exposure, you may line out or remove the case from the 300 Log if:

  • The worker lives in a household with a person who was diagnosed;
  • The Public Health Department identified the worker as a contact of an individual with a case unrelated to the workplace; or
  • A medical investigation shows that the employee’s infection was caused by exposure away from work, or proves that the case was not related to the workplace exposure.

Respirator use

The CDC does not recommend the use of face masks for the general public to prevent infection. Instead, the CDC recommends frequently washing hands with soap and water for at least 20 seconds; avoiding touching eyes, nose, or mouth with unwashed hands; and avoiding close contact with people who are sick.

Still, employees might voluntarily choose to wear surgical masks or filtering facepiece respirators. If you allow voluntary use of filtering facepiece respirators, you must determine that such use will not itself create a hazard and provide a copy of Appendix D of the respiratory protection standard to each voluntary user. However, OSHA doesn’t consider a surgical mask to be a respirator, even if the employer provides them, so that voluntary use does not create obligations on the employer.

A big thank you to JJ Keller for the content of this post.