{"id":895,"date":"2021-03-22T13:16:38","date_gmt":"2021-03-22T17:16:38","guid":{"rendered":"https:\/\/caloshadefensereport.com\/?p=895"},"modified":"2026-03-15T16:51:51","modified_gmt":"2026-03-15T16:51:51","slug":"six-important-updates-about-cal-osha-and-federal-osha-covid-19-recordkeeping","status":"publish","type":"post","link":"https:\/\/www.connmaciel.com\/calosha-defense-report\/six-important-updates-about-cal-osha-and-federal-osha-covid-19-recordkeeping\/","title":{"rendered":"Six Important Updates About Cal\/OSHA and Federal OSHA COVID-19 Recordkeeping"},"content":{"rendered":"

By Conn Maciel Carey\u2019s\u00a0COVID-19 Task Force<\/a><\/strong><\/em><\/p>\n

It has been a little while since we last shared an update about COVID-19 recordkeeping issues. Since\u00a0Fed OSHA issued its COVID-19 recordkeeping guidance in May 2020<\/a>\u00a0and\u00a0Cal\/OSHA issued its controversial COVID-19 Recordkeeping FAQs with unique requirements,<\/a>\u00a0the agencies have been mostly quiet about COVID-19 recordkeeping. But that does not mean there have not been significant developments in that area or that there are no important developments to monitor closely.<\/p>\n

Here are six notable COVID-19 recordkeeping (and general reporting) updates that we wanted to share with you:<\/p>\n

1.\u00a0 Congressional Intervention About Cal\/OSHA\u2019s COVID-19 Recordkeeping FAQs<\/strong><\/p>\n

As we explained last year,\u00a0Cal\/OSHA\u2019s May 27th COVID-19 Recordkeeping FAQs<\/a>\u00a0departed from Fed OSHA\u2019s COVID-19 recordkeeping requirements in two key ways: (i) rejecting Fed OSHA\u2019s recordability precondition of a positive COVID test; and (ii) flipping the burden of establishing work-relatedness on its head,\u00a0\"Cal-OSHA<\/a>setting instead a presumption of work-relatedness if\u00a0any<\/em>\u00a0workplace exposure can be identified, even if the cause of the illness is just as likely to be attributable to a non-work exposure.<\/p>\n

Aside from being bad policy that will result in many non-work related illnesses being recorded on California employers\u2019 300 Logs, Cal\/OSHA is not legally permitted to deviate from Fed OSHA\u2019s recordkeeping requirements.<\/p>\n

The latest big development on that front was a helpful letter from the U.S. Department of Labor responding to an inquiry about this issue from a group of California Congressmen, in which DOL confirms that Cal\/OSHA should be following the same recordkeeping requirements as Fed OSHA. Despite the clear statements in Cal\/OSHA\u2019s FAQs that a \u201cconfirmed case\u201d is not required for recordkeeping and that work-relatedness should be presumed, the federal Department of Labor explained in its letter to the Congressmen:<\/span><\/p>\n

\u201cThe FAQs reference federal OSHA\u2019s guidance and state that \u2018a COVID-19 case should generally be confirmed through testing to be recordable,\u2019 consistent with federal OSHA.\u00a0 We note the suggestion that there may be some instances of recordable cases without testing is limited to rare situations, such as where testing is not available.\u00a0 Cal\/OSHA advises that it has not issued any recordkeeping citations without a confirmed COVID-19 case.\u201d<\/em><\/p>\n

\u201cOSHA believes that Cal\/OSHA\u2019s guidance with respect to work-relatedness is also consistent with OSHA\u2019s guidance\u2026.\u201d<\/em>\u00a0\u00a0Here, DOL goes even further, essentially suggesting that Cal\/OSHA\u2019s FAQs should not be given weight: \u201c[G]uidance on Cal\/OSHA\u2019s website makes clear that the FAQs are not a substitute for the recordkeeping standard.\u00a0 Thus, the recordkeeping standard itself\u2014not Cal\/OSHA\u2019s FAQs\u2014governs the recordability of these cases<\/em>.\u201d\u00a0 Ultimately, DOL offered that \u201c[t]o the extent Cal\/OSHA\u2019s FAQs appear to create any significant difference between the state and federal COVID-19 recordkeeping requirements, OSHA will work with Cal\/OSHA to consider clarifying changes to its FAQs.<\/em>\u201d<\/p><\/blockquote>\n

Here is a link<\/a> to a copy of the letter from DOL to the California Congressmen.<\/p>\n

2. President Biden\u2019s OSHA Passed on an Early Opportunity to Change Fed OSHA\u2019s COVID-19 Recordkeeping Guidance<\/strong><\/p>\n

As much as we have been encouraging Cal\/OSHA to realign its COVID-19 recordkeeping requirements with federal OSHA\u2019s less burdensome position, we have been worried that federal OSHA, now under a Biden Administration, would move the national COVID-19 recordkeeping position to align with Cal\/OSHA\u2019s more burdensome interpretation.\u00a0 Fed OSHA just had a major opportunity to do precisely that and passed on it.\"\"<\/a><\/p>\n

Specifically, OSHA just announced significant updates to its\u00a0Interim Enforcement Response Plan<\/a>, which details how OSHA\u2019s field staff should conduct COVID-related inspections.\u00a0 That response plan happens to be the same tool that OSHA has used to detail for the public the agency\u2019s position about COVID-19 recordkeeping.\u00a0 If OSHA was going to offer a less generous position on COVID recordkeeping, it would start by updating this Interim Enforcement Response Plan to change or delete that guidance.\u00a0 OSHA may still do that at some point, perhaps through the COVID-19 emergency rulemaking that is underway right now, but it did not disturb that guidance in the updated response plan last week, which is a good sign.<\/p>\n

3. COVID-19 Recordkeeping Enforcement<\/strong><\/p>\n

To date, injury and illness recordkeeping and reporting has been Fed OSHA\u2019s 2nd\u00a0most frequently cited category of regulatory requirements in the COVID-19 context<\/a>\u00a0(behind respiratory protection requirements related to N95 use in healthcare settings).\u00a0 That may change after OSHA issues a COVID-19 emergency temporary standard, which we expect soon.\u00a0\"\"<\/a>\u00a0In the meantime, it seems the OSHA Area Offices are taking a more aggressive view of work-relatedness than fed OSHA COVID-19 recordkeeping guidance suggests is appropriate.\u00a0 Many of those alleged recordkeeping violations are in active contest before the OSH Review Commission right now.<\/p>\n

Relevant to the Cal\/OSHA recordkeeping controversy discussed above, we have been trying to monitor Cal\/OSHA\u2019s COVID-related enforcement throughout the year, and to date, we have not yet seen any Cal\/OSHA COVID-related recordkeeping violations for cases that would not also have been recordable in a fed OSHA state.\u00a0 We may have missed some, but it is clear enough that as of now, this has not been an enforcement priority for Cal\/OSHA.\u00a0 That could change in the near term, or because of the new five-year statute of limitations Cal\/OSHA has for recordkeeping violations, it could be something California employers have to deal with a little ways down the road.<\/p>\n

4.\u00a0 Exempting COVID-19 From Recordkeeping<\/strong><\/p>\n

At the beginning of the pandemic, OSHA declined to apply the recordkeeping flu exemption to COVID-19 despite the fact that COVID-19 proliferates in the same way as the cold and flu \u2013 it is invisible; it is ubiquitous; and it is not unique to the workplace \u2013 which is the reason why the cold and flu have always been exempt from OSHA injury and illness recordkeeping.\u00a0 Regrettably, thus far, OSHA has decided that exemption written into the recordkeeping regulations is very narrow; i.e., it applies only to specific cold and flu diagnoses, and thus, confirmed COVID-19 cases are not exempt from recordkeeping.\u00a0 OSHA has not believed that it could lawfully apply such an exemption by policy even if it wanted to; rather, it would have amend the regulatory text.<\/p>\n

Since Federal OSHA is currently engaged in a COVID-19 emergency rulemaking right now, we have been recommending to Fed OSHA that it include a COVID-19 recordkeeping exemption in its ETS (in conjunction with establishing a separate COVID-19 tracking system).\u00a0 In connection with that rulemaking, we have had a couple of opportunities to share our input and recommendations to OSHA directy, including about the burden of COVID-19 recordkeeping.\"\"<\/a>\u00a0 We were one of a few employer groups to participate in a Listening Session with OSHA to share our concerns and recommendations as OSHA was drafting the ETS.\u00a0 Then, despite fed OSHA not publishing a proposed rule for public comment, we nevertheless submitted a comprehensive set of\u00a0written comments and recommendations to Fed OSHA and OMB<\/a>\u00a0about the potential fed OSHA ETS.\u00a0 As part of our long-running effort to ease the COVID-19 recordkeeping burden on employers in all states, we advocated strongly that fed OSHA should use this emergency rulemaking to exempt COVID-19 from 300 Log recordkeeping, just like the cold and flu.\u00a0 Fingers crossed OSHA sees the logic in that decision.<\/p>\n

If that did develop, that would also be very significant in California and other State Plan states.\u00a0 Consistent with the position we have been advancing to OSHA and Cal\/OSHA throughout the pandemic, since all State Plans must follow fed OSHA\u2019s lead on recordkeeping (in terms of what has to be recorded and how to record it), if fed OSHA exempts a particular illness from recordkeeping, all of the State Plans would also be obligated to exempt it from their recordkeeping requirements.<\/p>\n

5.\u00a0 COVID-19 Vaccination-Related Recordkeeping Issues<\/strong><\/p>\n

OSHA has fielded a few questions lately about the recordability of bad vaccine reactions in the context of both mandatory and voluntary workplace vaccination programs.\u00a0 The agency has shared some feedback already, but there is still some lack of clarity.\u00a0 What we do know is that OSHA representatives have stated that reactions to the vaccine in the context of an\u00a0employer-mandated vaccination program<\/em>\u00a0would be considered work-related, and would be recordable on the 300 Log if the reactions required medical treatment beyond first aid or days away from work.<\/p>\n

What we know about recordability in the absence of an employer\u2019s explicit vaccine mandate is less clear.\u00a0 On one hand, OSHA\u2019s longstanding general rule is that injuries\/illnesses that result solely from\u00a0voluntary<\/em>\u00a0participation in a medical activity like a flu shot program are\u00a0not<\/em><\/strong>\u00a0work-related.\u00a0\u00a0See\u00a0<\/em>29 C.F.R. 1904.5(b)(2)(iii).\u00a0 On the other hand, OSHA has long explained that an employee\u2019s vaccination should be considered work-related, even in the absence of an explicit vaccine mandate, if the vaccine is needed for the employee to perform his\/her job duties, which OSHA says is the case when \u201cthe vaccine is provided to protect the employee from exposure in the work environment.\u201d\u00a0\u00a0See\u00a0<\/em>OSHA Injury and Illness Recordkeeping and Reporting Requirements Q&A Search, FAQ ID: 375 (related to the smallpox vaccine);\u00a0see also\u00a0<\/em>Preamble to the Final Rule on Occupational injury and Illness Recording and Reporting Requirements, 66 FR 5916 (stating that an employee\u2019s reaction to a vaccine received for travel overseas on business is work-related).<\/p>\n

Thus far, OSHA has refused to treat COVID-19 like the flu with respect to recordkeeping obligations.\u00a0 We think OSHA is likely to take a similar approach here to serious reactions to the COVID-19 vaccine, as there are dissimilarities between the COVID-19 vaccine (and employee\u2019s decisions to get it) and vaccines for the flu.\u00a0\"\"<\/a>\u00a0OSHA is more likely to determine a COVID-19 vaccine (as compared to a flu vaccine) is necessary to protect employees from exposure in the work environment, particularly at work environments that OSHA views as higher risk. That is especially likely for the industries covered by\u00a0OSHA\u2019s new COVID-19 National Emphasis Program<\/a>.\u00a0 Application of that kind of interpretation in low risk exposure workplaces would be a stretch, because it would be difficult for OSHA to show the vaccine is any more necessary for the employee\u2019s job duties than it is for his or her personal life outside the workplace.<\/p>\n

Until we get some more clarity from OSHA about this, to the extent it is feasible, we recommend trying to keep track in some form employee vaccine reactions that require medical treatment or days away, especially for vaccinations received during an event coordinated at the workplace.<\/p>\n

6. New OSHA Interpretation Letter About Double Reporting Hospitalizations and Fatalities<\/strong><\/p>\n

Finally, although not exclusive to COVID-19, we wanted to share some other OSHA recordkeeping \/ reporting news \u2013 a helpful clarification about \u201cdouble reporting\u201d to federal OSHA.\u00a0 In response to advocacy by CMC\u2019s OSHA team, OSHA issued a formal letter of interpretation that confirms a position we have been pushing with fed OSHA through a series of contested cases and inspection disputes.\u00a0 Specifically, we have been advocating that pursuant to OSHA\u2019s\u00a0hospitalization, amputation, and fatality reporting rule<\/a>, employers are\u00a0not required to submit a second report\u00a0<\/em>to OSHA regarding a fatality or other reportable event, if the employer had already reported the incident to OSHA based on an initial reportable outcome.\"\"<\/a>\u00a0\u00a0For example, if an employee\u2019s hospitalization is reported to OSHA, and that employee should unfortunately later succumb to the same injury or illness, that more severe outcome is not separately reportable, nor would be a medical-amputation that follows an already-reported hospitalization.<\/p>\n

The second report is not required because the initial report to OSHA provides the agency all the notice it needs to begin its own investigation (either through an on-site inspection or the new Rapid Response Investigation protocol).\u00a0 Here is\u00a0a link to the new interpretation letter posted on OSHA\u2019s website<\/a>.\u00a0 This interpretation limits the number (and nature) of reports employers must make to OSHA.<\/p>\n

*****<\/p>\n

Conn Maciel Carey LLP
\nDisclaimer<\/a>
\nAttorney Advertising<\/p>\n","protected":false},"excerpt":{"rendered":"

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Since\u00a0Fed OSHA issued its COVID-19 recordkeeping guidance in May 2020\u00a0and\u00a0Cal\/OSHA issued its controversial COVID-19 Recordkeeping…<\/p>\n","protected":false},"author":4,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"_price":"","_stock":"","_tribe_ticket_header":"","_tribe_default_ticket_provider":"","_tribe_ticket_capacity":"","_ticket_start_date":"","_ticket_end_date":"","_tribe_ticket_show_description":"","_tribe_ticket_show_not_going":false,"_tribe_ticket_use_global_stock":"","_tribe_ticket_global_stock_level":"","_global_stock_mode":"","_global_stock_cap":"","_tribe_rsvp_for_event":"","_tribe_ticket_going_count":"","_tribe_ticket_not_going_count":"","_tribe_tickets_list":"[]","_tribe_ticket_has_attendee_info_fields":false,"footnotes":"","_links_to":"","_links_to_target":""},"categories":[449],"tags":[423,36],"class_list":["post-895","post","type-post","status-publish","format-standard","hentry","category-legislative-standards-board-updates","tag-infectious-diseases","tag-injury-illness-recordkeeping-reporting-300-300a-301"],"acf":[],"yoast_head":"\nSix Important Updates About Cal\/OSHA and Federal OSHA COVID-19 Recordkeeping - Cal\/OSHA Defense Report<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.connmaciel.com\/calosha-defense-report\/six-important-updates-about-cal-osha-and-federal-osha-covid-19-recordkeeping\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Six Important Updates About Cal\/OSHA and Federal OSHA COVID-19 Recordkeeping - Cal\/OSHA Defense Report\" \/>\n<meta property=\"og:description\" content=\"By Conn Maciel Carey\u2019s\u00a0COVID-19 Task Force It has been a little while since we last shared an update about COVID-19 recordkeeping issues. 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