Updated OSHA Guidance On Reporting

The Occupational Safety and Health Administration (OSHA) has released  guidance regarding the employer’s obligation to record adverse reactions by employees when they received the COVID-19 vaccine.  The guidance addresses the employer’s requirements if a mandatory vaccination policy has been implemented for the workplace.  If the employer does require employees to be vaccinated as a condition of employment, then any adverse reaction to the vaccine would be considered work related if the reaction meets the criteria for recordability for OSHA’s Form 300, Log of Work-Related Injuries, and Illnesses.

If a mandatory policy has been implemented, then any adverse reaction is recordable if it led to the employee missing more than one day work, medical attention beyond first aid is required, or the reaction resulted in restricted work or transfer to another job. OSHA has a very specific list of actions that it considers first aid so that list needs to be consulted in determining the recordability of an incident.  

Employers that only recommend the vaccine to their employer, but do not require it, are not required to record adverse reactions.  To be truly voluntary, the employee’s choice to accept or reject the vaccine cannot have any negative impact on the employee, including any impact on their performance rating or professional advancement.  Unless the employee is totally free to choose whether or not to receive the vaccine without fear of adverse action, then the vaccine cannot be considered “recommended.”

For more information on this recording update, or if you have any questions, please contact PRINTING United staff at govtaffairs@printing.org.