Back in April of last year, we recapped a memo from OSHA that provided revised guidance to employers for COVID-19 recordkeeping requirements due to the pandemic. The new guidelines pertained to all employers that are not in the healthcare industry, emergency response organizations (e.g., emergency medical, firefighting, and law enforcement services) or correctional institutions. The memo referred to these employers as “other.” 


At that time, OSHA temporarily changed the requirement for these “other” employers to determine work relatedness of COVID-19 cases unless there is objective evidence that a COVID-19 case may be work-related and the evidence was reasonably available to the employer. The memo gave the example for objective evidence of a situation where several employees who work closely together develop COVID-19 cases without an alternate explanation.


One of President Biden’s first executive orders after taking office was to direct OSHA to issue new guidance to employers for protecting workers from COVID-19. The guidance is to come within the next two weeks, and employers are expecting an end to the relaxed recordkeeping and reporting requirements related to COVID-19 cases issued last year.


Revised guidelines could require quick adjustments by employers

Throughout the pandemic, employers have had to quickly adapt to changing requirements, safety protocols, work situations and more. Now, as employers await the new guidelines from OSHA, many have questions about what the specific changes will be, how the changes will affect their processes for recordkeeping and reporting as it relates to COVID-19 cases, and the timeframes for implementing the changes.


Employers that have electronically maintained employee health records throughout the pandemic will be better poised to meet whatever new reporting requirements are set forth. 


Health information technology has been instrumental in helping employers effectively manage many aspects of the COVID-19 pandemic from symptom monitoring, case management and work status to contact tracing and now vaccine administration. Access to this data will simplify employers’ ability to report to OSHA and maintain compliance.  


Other possible changes to COVID-19 standards and practices

The executive order directs OSHA to reevaluate several other standards and practices in addition to COVID-19 recordkeeping requirements. OSHA is expected to take the following actions:

  • consider if emergency temporary standards for COVID-19 are needed, and if so, issue them by March 15;
  • review enforcement practices for the pandemic and identify any needed changes;
  • launch a national program centered on the agency’s enforcement protocols; and
  • work with the Labor Department's public affairs and public engagement offices and all regional OSHA offices on a multilingual outreach campaign to educate workers on their rights.

As employers await the new guidelines, they should take a moment to consider how prepared their organization is to manage all types of work-related injuries and illnesses. Watch this short video to see the functionality Enterprise Health provides to simplify recordkeeping and OSHA reporting.  


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