Inquiry from Client

I have a question related to COVID cases being an OSHA recordable event.  Our location has seen a surge in positive cases, and it has hit the company operation.  We had an employee test positive and our investigation revealed that other positive cases could be easily linked to the initial case.
      1. If I understand the rule, the linked cases would be considered an OSHA recordable, is that correct?
      2. If so, my next question would be regarding a lost time incident.  Since a positive test requires isolation, that would make the case a recordable, correct?
      3. Then if so, would you then count just the isolation days or would you also count the days the employee was off work waiting for the results of the COVID test to come back?

 Director of EHS and Facilities

Midwest Metal Stamping Plant

 

Answer from David Blane

Although, OSHA’s guidance on its website is not specifically for COVID-related cases, the general information is still applicable for this type of occupational illness.  My response to your questions is below.
      1. If, after your investigation, you believe the linked cases were occupationally incurred, then yes, the cases are recordable.
      2. Isolation is not what makes the case recordable. Diagnosis of a significant illness is the trigger for recording the incident.  Isolation just goes towards to number of days missed.
      3. Unless a doctor could tell you specifically when the worker contracted the disease, you would only count the days after the diagnosis was received. That is, you don’t count the first day you get the diagnosis, but you count each day thereafter that the employee is away from work.
If you would like to review the OSHA guidance used to derive these conclusions, please access the following links: http://www.osha.gov/memos/2020-05-19/revised-enforcement-guidance-recording-cases-coronavirus-disease-2019-covid-19 https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=directives&p_id=3205 http://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.7

David Blane

Senior Health and Safety Specialist, CSP

Cornerstone Environmental, Health and Safety

 
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