On May 19, 2020 OSHA issued a memorandum for each Regional Administrator and State Plan designees revising enforcement guidelines for recording cases of COVID-19 on your companies 300 Log.
Under OSHA’s recordkeeping requirements, COVID-19 is a recordable illness, and employers are responsible for recording these cases. This will be a challenge for employers because they will need to confirm that the case is COVID-19 as defined by the CDC, determine if it is work-related, and does meet the general recording criteria set forth in 29 CFR 1904.7. Recording these cases does not necessarily mean that an employer has violated an OSHA standard but, increasing the number of illnesses on your 300 Log may affect the ability to bid and secure future work. Many company’s use your Experience Modifier Rate (EMR) and your 300 Log to determine the quality and effectiveness of your Health and Safety Program. The challenge will be determining whether or not the employee contracted COVID-19 at the workplace or from another source. We recommend that you continue implementing your Engineering, Administrative, and PPE controls, and clean with Clorox or an alcohol-based product on a regular basis. Follow all guidelines that are established by your local government and the CDC.
Pat Miller and out friends over at Sherman & Howard are following this closely and are providing updated information. Pat told us that, “…the Colorado General Assembly is trying to pass legislation that would make it a presumption that a worker with COVID-19 got it at work and that comp (Workers Compensation) applies. It would be up to the employer to disprove it.”
We will continue to provide you with updates and can assist in determining if a case should or should not be recorded on you 300 Log, as well as keeping you informed of all of the latest updates from OSHA.
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