OSHA’s New Guidance on Recordability of COVID-19 Vaccine Reactions Thursday, April 22, 2021
he U.S. Occupational Safety and Health Administration (OSHA) has answered a question that has been troubling employers since the pace of vaccinations started to accelerate: when must an employer record an adverse reaction to a COVID-19 vaccine on its OSHA 300 Logs? In a new series of answers to its COVID-19 frequently asked questions (FAQs) issued on April 20, 2021, OSHA states that the answer turns on whether the vaccine is required or recommended by the employer. The new guidance makes clear that while adverse reactions to required and recommended vaccinations may be recordable, “OSHA is exercising its enforcement discretion to only require the recording of adverse effects to