Some industries are required to keep OSHA injury and illness logs including 300, 300A, and 301s. Healthcare is one of those industries and normally logs encompass the following requirements: type of injury, death, loss of consciousness, days away from work, restricted work activity or job transfer, and medical treatment beyond first aid.               

Healthcare employers are also required to record significant illness or injury that is work-related such as:

• Any needle-stick injury or cut from a sharp object that is contaminated with another person’s blood or potentially infectious material
• Any case requiring an employee to be medically removed under the requirements of an OSHA health standard (like the current ETS)
• TB infection
• Standard threshold shift in hearing in one or both ears

Additional OSHA COVID Log

Pursuant to OSHA’s COVID-19 Emergency Temporary Standard (ETS) issued this summer, in addition to the standard 300 logs, healthcare-based employers must now also create a secondary COVID log for those infections which do not meet the 300 standards. The COVID-19 log may be obtained on OSHA.gov. 

It should include the employee’s name and occupation, contact information, employee work location, last day the employee was in the workplace, date of diagnosis or positive test, date of onset of symptoms, and a brief description of any and all additional information. This log applies whether or not the employee may have been exposed to COVID in the workplace. 

No Geographical Limits

This standard does not apply to employers with 10 or fewer employees but note that this is an aggregate standard. In other words, it applies if you have 10 or more employees in the company as a whole, there is no geographical limitation like there is with the Family and Medical Leave Act. Further employee counts include “all full-time, part-time and temporary and seasonal employees.” 

Remote Employees

However, employees who work “exclusively from home” and will not otherwise be exposed and may not expose others in the workplace do not need to be included on such a log.  But if an employee comes in for a meeting, drops documents off, or attends the unit’s birthday lunch, then they are not actually a remote employee. The time frame for completing the log is within 24 hours of reporting symptoms or 24 hours of a confirmed positive test or diagnosis.

The Big Picture

Employers are required to make the logs available to the employee, employer representatives, and OSHA by the end of the “next business day after request.” There are limitations on employee inquiries, but all information can be accessed by OSHA. Failure to comply can result in fines and penalties.

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