Updated: COVID 19: OSHA Recordable Illness Information

For the latest information and resources on Coronavirus, please visit the RCM&D COVID-19 Resource Center at

What you need to know:

Under OSHA’s recordkeeping requirements, COVID-19 is a recordable illness. Employers are responsible for recording cases of COVID-19 if:

(1) the case is a confirmed case of COVID-19, as defined by Centers for Disease Control and Prevention (CDC);[1] (2) the case is work-related as defined by 29 CFR § 1904.5;[2] and (3) the case involves one or more of the general recording criteria set forth in 29 CFR § 1904.7. [3] On March 11, the World Health Organization (WHO) declared COVID-19 a global pandemic, and the extent of transmission is a rapidly evolving issue.

Who does it affect:

All employers who fall under the OSHA Recordkeeping Rule 29 CFR part 1904.

Why it’s Important:

OSHA mandatory recordkeeping regulations provides the information needed to identify and target potential enforcement actions those establishments with high rates of work-related injuries and illnesses.  Failure to provide OSHA with accurate recordkeeping information may potentially violate Recordkeeping Rule 29 CFR part 1904.  Violations of this rule may result in monetary fines and further enforcement actions.

Current OSHA Reporting Criteria is Applicable to Work Related COVID-19 Exposure:

How to Determine if a COVID-19 Case is Recordable:

COVID-19 can be a recordable illness if a worker is infected as a result of performing their work-related duties. However, employers are only responsible for recording cases of COVID-19 if all of the following are met:

Interpretation of COVID-19 Recordable Cases:

  1. An employee of XYZ Healthcare tends to a patient who has tested positive for COVID-19.  Days later, the employee tending to the patient who tested positive for COVID-19 becomes ill. Upon being tested, the employee is confirmed to have contracted COVID-19.  This case would be recordable as it is known direct contact with COVID-19 was established via the working environment.
  2. An Employee working as a retail cashier suddenly became ill during work hours after assisting numerous customers during a busy work week.  The Employee sought medical care where it was determined that they tested positive for COVID-19.  There are no known cases of COVID-19 at the retail employer.  Since this is the first case effecting the employer and there is no confirmed/known source, the case would not be recordable.  Subsequent cases of COVID-19 effecting retail employees that occurred after the first known cashier case would be recordable.

COVID-19 Frequently Cited OSHA Standards:

For more information please view:

OSHA COVID-19 Preparation:

OSHA Enforcement Guidance:

OSHA COVID-19 Enforcement Memorandum:

OSHA COVID-19 Recordkeeping:

OSHA Recordkeeping Rule:

OSHA Recordkeeping FAQ:

CDC COVID-19 Information: