OSHA and COVID - 19

Answers to a few of the most-discussed OSHA questions during COVID-19.


Coronavirus has had an impact on the ability of businesses to perform. It is prudent for businesses to review the information that may have lasting results on their relationships impacted by this pandemic.


Is COVID -19 a recordable illness for purposes of OSHA Logs?

OSHA recordkeeping requirements at 29 CFR Part 1904 mandate covered employers record certain work-related injuries and illnesses on their OSHA 300 log.

COVID-19 can be a recordable illness if a worker contracts the virus while on the job.  The illness is not recordable if the worker was exposed to the virus while off the clock. Essentially, employers are only responsible for recording cases of COVID-19 if ALL the following are met:

  1. The case is a confirmed case of COVID-19 (see CDC information on persons under investigation and presumptive positive and laboratory-confirmed cases of COVID-19);
  2. The case is work-related, as defined by 29 CFR 1904.5; and
  3. The case involves one or more of the general recording criteria set forth in 29 CFR 1904.7(e.g. medical treatment beyond first-aid, days away from work).

Visit OSHA’s Injury and Illness Recordkeeping and Reporting Requirements page, or contact your IMA Risk Control Advisor for more information.

Download OSHA Best Practices

Follow existing OSHA standards

Existing OSHA standards may apply to protecting workers from exposure to and infection with SARS-CoV-2.

While there is no specific OSHA standard covering SARSCoV-2 exposure, some OSHA requirements may apply to preventing occupational exposure to SARS-CoV-2. Among the most relevant are:

  • OSHA’s Personal Protective Equipment (PPE) standards (in general industry, 29 CFR 1910 Subpart I), which require using gloves, eye and face protection, and respiratory protection.

When respirators are necessary to protect workers or where employers require respirator use, employers must implement a comprehensive respiratory protection program in accordance with the Respiratory Protection standard (29 CFR 1910.134). See:

  • The General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health (OSH) Act of 1970, 29 USC 654(a)(1), which requires employers to furnish to each worker “employment and a place of employment, which are free from recognized hazards that are causing or are likely to cause death or serious physical harm.” See:

For more information on OSHA requirements and COVID-19, refer to OSHA’s Guidance on Preparing Workplaces for COVID-19 at

IMA is a Resource

Need a checklist for COVID-19 while continuing to work?  Know that IMA’s Risk Management Center (RMC) has a simple audit checklist. If you haven’t availed yourself in the past to our RMC, all clients can register at